Senior Financial Products Tax Associate / Special Counsel

Fried, Frank, Harris, Shriver & Jacobson LLP; Washington (District of Columbia); Sur place; USD 180 000 - 240 000; Plein temps

Résumé du poste

Fried, Frank, Harris, Shriver & Jacobson LLP in Washington, DC seeks a tax attorney with substantial experience in U.S. federal income tax treatment of financial instruments and products.

The role focuses on inbound fund issues for debt, derivatives, and commodities, with expertise in cross-border transactions. The successful candidate will draft tax opinions and memoranda, collaborate with trading desks and structuring teams, and mentor junior attorneys while supporting business development

Qualifications

• Substantive experience advising on U.S. federal income tax treatment of financial instruments and products.
• Experience advising investment funds on inbound U.S. tax issues from debt, derivatives, and commodities.
• Ability to draft tax opinions, private letter ruling requests, and technical memoranda.

Responsabilités

• Advise financial institutions, asset managers, trading firms, or related groups on complex U.S. tax issues.
• Draft or review tax opinions and memoranda for trading desks and structuring groups.
• Supervise and mentor junior attorneys and contribute to business development.

Connaissances

U.S. federal income tax

Tax opinions drafting

Inbound U.S. tax issues for funds

Cross-border tax issues

Mentoring junior team members

Client relationship management

Formation

Juris Doctor (JD)

Description du poste

Overview

• The role requires substantive experience advising on the U.S. federal income tax treatment of financial instruments and products.
• Key areas of experience include advising investment funds on inbound U.S. tax issues from positions in debt, derivatives, and commodities (including ECI and "dealer" risk), as well as expertise in debt instruments (original issue discount, contingent payment, distressed debt, Section 1001), derivatives (Section 1256 contract rules), structured products, notional principal contracts, and hybrid instruments.
• Experience should also cover constructive sale, straddle, and wash sale rules (Sections 1259, 1092, 1091), Section 1221 hedge identification rules, withholding tax issues (Sections 871(m), 1441, 1442) for cross-border financial products, and taxation of hedge funds, regulated investment companies, and other pooled investment vehicles holding financial instruments.
• Preferred experience includes advising financial institutions, asset managers, trading firms, broker-dealers, or corporate treasury groups on new or novel financial products, including drafting or reviewing tax opinions, and familiarity with relevant IRS guidance, Treasury regulations, and case law governing financial instruments.
• The role involves strong technical drafting skills for tax opinions, private letter ruling requests, and technical memoranda, and the ability to work directly with trading desks, structuring groups, or capital markets teams to analyze tax consequences and translate complex tax concepts for non-tax professionals.
• Experience supervising and mentoring junior team members is preferred, with a demonstrated record of business development and client relationship management being a plus for special counsel candidates.