Alternative Investments Tax Staff through Managers

Job Description

Job Description

• Research various federal and international tax issues including debt to equity analysis, IRC 338(h)(10) election, conduit financing, FDAP withholding and Derivatives Taxation.

• Draft various tax memos and provide recommendations specifically on debt to equity analysis, conduit financing, IRC 338(h)(10) filing, derivatives taxation and other tax matters.

• Advise the functional leadership in the various groups as to the tax risks and/or exposure on transactions including the effect on a mixed straddle transactions, unwinding of structures and derivative terminations.

• Actively involved in developing a process for the US Federal Foreign Bank Account Reporting (FBAR) filing for U.S. entities and U.S. individuals worldwide.

• Research relevant treaties pertaining to withholding tax and other areas.

• Undertook the review of the Princeton Asset Management system (PAM), which included research and analysis of the tax elections in the PAM system.

• Undertook analysis of the tax treatment of derivatives and prepared matrix recommending proper tax treatment of derivatives.

• Provided quantitative analysis as the tax effect on the termination of interest rate swaps in a U.S. entity and made a recommendation as to an accounting method change.

• Work with external tax advisor as necessary on projects including the unwind of structures, method of accounting change.

• Draft response to Information Document Request (IDRs), specifically pertaining to derivatives.

• Researched and drafted a memo on the transfer pricing effect on the debt to equity analysis.

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