Tax Senior Associate / Special Counsel (Financial Products Focus)

We are looking for a senior tax associate or special counsel with experience in advising in the taxation of financial products or financial instruments in DC or NY. Ideal candidate will have 6+ years of relevant tax experience at a law firm or accounting firm.

Substantive experience advising on the U.S. federal income tax treatment of financial instruments and products, which may include some combination of:

• Advising investments funds on inbound U.S. tax issues arising from positions in debt instruments, derivatives, and/or commodities (e.g., ECI issues for credit funds and/or “dealer” risk).

• Debt instruments, including original issue discount (OID), contingent payment debt instruments, distressed debt issues, and modifications/exchanges under Section 1001.

• Derivatives (swaps, options, forwards, futures) and the Section 1256 contract rules.

• Structured products, notional principal contracts, and hybrid instruments.

• Constructive sale, straddle, and wash sale rules (Sections 1259, 1092, 1091).

• The Section 1221 hedge identification rules.

• Withholding tax issues under Sections 871(m), 1441, and 1442 for cross-border financial products.

• Taxation of hedge funds, regulated investment companies (RICs), and other pooled investment vehicles holding financial instruments.

Additional preferred skills and experience:

• Experience advising financial institutions, asset managers, trading firms, broker-dealers, or corporate treasury groups on the tax treatment of new or novel financial products, including drafting or reviewing tax opinions.

• Familiarity with relevant IRS guidance, Treasury regulations, and case law governing the character, timing, and source of income from financial instruments.

• Strong technical drafting skills, including experience preparing tax opinions, private letter ruling requests, and technical memoranda.

• Ability to work directly with trading desks, structuring groups, or capital markets teams to analyze the tax consequences of proposed transactions and new products.

• Excellent analytical, written, and verbal communication skills, with the ability to translate complex tax concepts for non-tax professionals.

• Exceptional collegiality and professionalism with colleagues, clients, and counterparts at other professional service firms.

• Experience supervising and mentoring junior team members.

• A demonstrated record of business development and client relationship management is a plus for special counsel candidates.

Candidate must be licensed to practice law or otherwise eligible for admission in the jurisdiction where they are applying.

The Firm pays market salaries to our attorneys. As such, below is the current associate base salary scale:

• 1st year: $225,000

• 2nd year: $235,000

• 3rd year: $260,000

• 4th year: $310,000

• 5th year: $365,000

• 6th year: $390,000

• 7th year: $420,000

• 8th year: $435,000