Director, US Funds Tax

Description

Alvarez & Marsal (A&M) is a global consulting firm with entrepreneurial, action and results-oriented professionals. We take a hands-on approach to solving our clients' problems and assisting them in reaching their potential. Our culture celebrates independent thinkers and doers who positively impact our clients and shape our industry. The collaborative environment and engaging work—guided by A&M's core values of Integrity, Quality, Objectivity, Fun, Personal Reward, and Inclusive Diversity—are why our people love working at A&M.

Alvarez and Marsal Tax’s U.S. Funds team is an exciting and unique opportunity. The team provides a broad range of U.S. tax compliance and reporting, as well as fund structuring and ad-hoc advisory services to European-based clients across many sectors in the Asset Management industry, such as Private Equity and Real Estate. The team is well placed to provide U.S. tax services, with a focus on international tax issues, to asset managers that have U.S. cross-border activity.

A&M is seeking ambitious and enthusiastic top-performing individuals to join the growing business and team.

In today’s increasingly complex global tax environment, having international reach, a strong local presence and the right expertise is critical to the successful execution of all client tax affairs.

• Lead complex U.S. tax advisory and reporting engagements across the private equity fund lifecycle, with responsibility for overall delivery, quality, and client service.
• Act as a senior point of contact for clients, providing practical and commercially focused advice on U.S. tax matters affecting fund structures, transactions, and cross-border investments.
• Build and deepen client relationships, identifying opportunities to expand A&M’s service offering and develop new areas of work.
• Lead U.S. tax work streams on fund formations, acquisitions and disposals, restructurings, and other complex transactions.
• Take an active role in business development, including developing opportunities, preparing proposals and pitches, networking, and building relationships across the market.
• Work collaboratively with colleagues across practices and jurisdictions to identify opportunities and deliver integrated solutions to clients.
• Lead, coach, and develop team members, providing technical guidance and creating opportunities for junior colleagues to take on greater responsibility.
• Contribute to the continued growth and development of the U.S. Funds practice, including improving processes, sharing technical knowledge, and supporting recruitment and team initiatives.

• CPA or EA qualified.
• Significant experience advising private equity, alternative investment fund and/or asset management clients on U.S. tax matters.
• Strong understanding of U.S. fund tax reporting, including Forms 1065, Schedules K-1 and K-3, and international information reporting such as Forms 8865, 5471, 8858 and 926.
• Strong understanding of U.S. international tax matters relevant to cross-border fund structures, including CFC, PFIC and QEF considerations, entity classification and check-the-box elections, and the U.S. tax consequences of changes in entity classification.
• Experience advising on the U.S. tax aspects of fund formations, acquisitions, disposals, restructurings, continuation funds and other complex transactions.
• Strong knowledge of ECI, FIRPTA and U.S. withholding regimes applicable to funds and their investors, including Sections 1445 and 1446, along with the relevant reporting Forms 1042 and 1042-S.
• Strong understanding of U.S. tax considerations for U.S. taxable, U.S. tax-exempt and non-U.S. investors, including ECI, UBTI and the use of…