Mid/ Senior-Level Tax Associate

The Department: With an unrivalled team of more than 150 personal and corporate tax lawyers, Withers is always ready to assist in domestic and international tax planning. Our advice is knowledgeable, reliable and solution-focused. We work with a broad range of successful individuals, families and companies on their interests in more than 100 countries. Our private clients include entrepreneurs, artists, athletes and city professionals. Corporate clients include many household names among fashion brands, financial services firms and hotel and hospitality companies.

The Role: The focus of this role will be to provide US tax advice to multi-national corporations on sophisticated cross-border tax issues, as well as high-net worth individuals and families in their personal business endeavors.  The role entails significant US cross border tax planning    

Skills and experience required:

• Strong academic credentials (JD required; LLM is a plus)
• 4-7 years' experience in a law firm's tax group or large accounting firm's tax consulting practice
• Admitted to, and in good standing with the State Bar of New York is required
• Strong drafting, writing, research and communication skills
  • Experience with Excel and PowerPoint a plus
• Experience with international cross-border tax structuring (inbound and outbound, including strong knowledge of Subpart F, GILTI, PFIC, permanent establishment, tax treaties and other significant tax areas).  Other areas of interest include:
  • Reference to "limitation on benefits tests" in connection with treaties
  • Inbound and outbound US federal and state nexus and "doing business" issues
  • Debt obligations, promissory notes, debt/equity analysis, and financial instruments
  • Familiarity with fund structures (private equity, venture, hedge, real estate) and associated taxation
• Experience working on a variety of closely held company, investment and joint venture matters, including corporate governance matters and transactions (real estate, M&A, private equity and fund work) on either the buyer or seller side, manager or investor side
• Experience drafting partnership and operating agreements and associated governance documents a plus
• Substantive experience advising clients in diverse tax issues, including integrated federal, state, international, estate and gift taxes
  • Experience with insurance, financial products, and taxation of compensation arrangements a plus.
• Desire to work directly with clients and coordinate with intermediaries, with a goal of establishing and maintaining long-term productive relationships
• Strong project management, ability to balance a large number of competing priorities
• Attention to detail
• Team Player