Tax Counsel

Millennium is a global investment manager that manages assets of funds and accounts, including its flagship multi‑manager, multi‑strategy hedge fund. The US Tax Counsel will join a dynamic Global Tax Team, reporting to the Head of US Tax Advisory, to help drive US tax strategy and risk management across the firm’s global operations. This role will work closely with key stakeholders, including colleagues within the Tax Team and broader Finance function, as well as Business Development, Trading, Investor Relations, and Legal & Compliance, to help advance strategic firm initiatives from a tax perspective.

• Analyze and advise on U.S. tax risks and tax laws impacting all aspects of the management company, GP, and funds’ current and anticipated future operations – including at the management company, fund level, feeder level, trading level, special projects, restructurings – to ensure appropriate tax risk management and compliance with applicable tax laws.
• Take ownership of the tax landscape and the impact on trading activity and/or operations of the fund.
• Analyze current and prospective trading products/strategies to identify areas of tax risks and implement appropriate investment structures.
• Meet with and answer questions from Portfolio Managers relating to the tax implications of their trading strategies.
• Review and comment on the tax aspects of various governing documents impacting the firm’s trading and operations, including ISDAs and trade confirmations, purchase agreements, partnership agreements, PPMs, offering memoranda and tax disclosures, and credit agreements.
• Work closely with/manage external advisor engagements including law firms and accounting firms.
• Help draft, implement and operationalize guidelines to manage tax risk.
• Assist in the review and analysis of corporate actions as needed.
• Work closely with tax compliance and operations colleagues to ensure appropriate reporting and implementation of tax planning and structuring initiatives as needed.

• 5+ years of experience working in practice (combination of Big Law firm and in‑house experience a plus).
• J.D. degree.
• Exposure to U.S. tax law (including inbound and outbound U.S. international tax) and investment structures – ideal candidate will have familiarity with partnership and corporate tax law as well as with formation and investment activity of open and closed‑ended funds.
• Experience with the following a plus: liquid trading, financial products, M & A, credit investing, international tax treaties, CLOs, REITs, capital markets issuances, PFICs, CFCs, 864b considerations, blocker structures, profits interest and carried interest planning, 457A, 409A, and U.S. foreign tax credits.
• Strong written, verbal, and analytical skills together with strong interpersonal and client service skills.
• Strong ability to collaborate, multi‑task and meet short deadlines in a fast‑paced environment, as well as advance complex projects with limited oversight.

The estimated base salary range for this position is $160,000 to $250,000, which is specific to New York and may change in the future. Millennium offers a competitive total compensation package that includes a base salary, discretionary performance bonus, and a comprehensive benefits package. When finalizing an offer, we take into consideration an individual’s experience level and the qualifications they bring to the role to formulate a competitive total compensation package.