Tax Senior Associate / Special Counsel (Financial Products)

We are seeking a senior tax associate or special counsel with deep experience advising on the taxation of financial products and instruments. The role is open to candidates in Washington, DC or New York and is suitable for a lawyer with 6+ years of relevant tax experience gained at a law firm or accounting firm.

The position focuses on the U.S. federal income tax treatment of a wide range of financial instruments and products. You will advise investment funds on inbound U.S. tax issues arising from positions in debt instruments, derivatives, and/or commodities, including ECI issues for credit funds and dealer risk. The work also involves debt instruments (original issue discount, contingent payment debt, distressed debt, and Section 1001 modifications/exchanges), derivatives (swaps, options, forwards, futures) and Section 1256 contracts, structured products, notional principal contracts, and hybrid instruments. You will handle constructive sale, straddle, and wash sale rules, hedge identification rules, and withholding tax issues for cross-border financial products, as well as the taxation of hedge funds, RICs, and other pooled investment vehicles.

Ideal candidates will also have 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 is important, along with strong technical drafting skills for tax opinions, private letter ruling requests, and technical memoranda. The role requires the ability to work directly with trading desks, structuring groups, or capital markets teams to analyze tax consequences of proposed transactions and new products. Excellent analytical, written, and verbal communication skills are essential, as is the ability to translate complex tax concepts for non-tax professionals. Experience supervising and mentoring junior team members is expected. A demonstrated record of business development and client relationship management is a plus for special counsel candidates.

• 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, including debt instruments, derivatives, structured products, and withholding tax issues
• Experience advising financial institutions, asset managers, trading firms, broker-dealers, or corporate treasury groups on new or novel financial products
• Strong technical drafting skills, including tax opinions, private letter ruling requests, and technical memoranda
• Ability to work directly with trading desks, structuring groups, or capital markets teams
• Excellent analytical, written, and verbal communication skills
• Experience supervising and mentoring junior team members
• Licensed to practice law or otherwise eligible for admission in the jurisdiction of application
• Business development and client relationship management experience is a plus for special counsel candidates