Senior Associate Attorney

Under the supervision of partners, provide legal advice and representation to clients, including financial institutions, private equity funds, institutional and individual investors, and U.S. and non-U.S. companies in various industries on a full range of deal-related tax questions and tax structuring involving corporate reorganizations, mergers and acquisitions, securities offerings, and restructuring transactions. Draft and negotiate contracts for corporate reorganizations and other taxable and tax-free mergers and acquisitions. Draft and negotiate private equity fund partnership agreements, side letters, offering memoranda, and subscription agreements. Negotiate tax structures and draft tax structuring step plans for restructuring transactions, corporate reorganizations and other taxable and tax-free mergers and acquisitions. Review, draft, and negotiate documents and contracts with respect to restructuring transactions, including bankruptcy plans, disclosures, transaction support agreements, debtor-in-possession credit agreements. Prepare legal memoranda summarizing the application of tax law regarding tax-free reorganizations, tax issues relating to restructuring, tax issues relating to structured financial products, international tax regime, and withholding regime. Review and submit private letter ruling requests to the Internal Revenue Service (IRS) on behalf of clients and prepare presentations. Submit comment letters to Treasury on behalf of clients lobbying for tax reform related regulations.

Requirements:Juris Doctor, Master of Laws, or foreign academic equivalent. Three years of legal experience involving corporate tax legal matters including with respect to mergers and acquisitions, private equity funds, restructuring transactions, structured financial products, and capital Three years of legal experience in using Excel spreadsheets for various tax analysis related to debt instruments. Three years of legal experience in drafting and reviewing tax disclosures for capital market transactions, including straight debt, contingent payment debt instruments, common stock, preferred stock, and convertible notes. Three years of legal experience in providing legal advice and representation to clients on a full range of deal-related tax questions involving capital markets transactions, restructuring transactions and credit agreements. Three years of legal experience in reviewing and negotiating stock and assets acquisition agreements and ancillary agreements for mergers and acquisitions. Three years of legal experience in reviewing pricing supplements for offerings of structured financial products under shelf registrations. Three years of legal experience in drafting tax memorandums and opinions with respect to a full range of deal-related tax issues.

Salary: $260,000.00 to $365,000.00 per year