Job Description

coni + partner, established 1993, is a consultancy company with headquarters in Zurich and subsidiaries in Düsseldorf and Shanghai. We specialise in custom‑fit staffing in tune with the corporate culture by ensuring a perfect match of professional skills, references and personal and social skills of successful candidates.

Job Title: Lawyer US Tax – Fund Transactions

Aufgaben

  • Ensure US tax compliance for management of private equity funds with appropriate consideration of risk, operational and tax issues
  • Ongoing analysis of US tax legislation and identification of impact on investments for portfolio management and investors
  • Analysis of distribution provisions in fund agreements and distribution allocation for investors
  • Analysis of international tax rules for PFICs or CFCs and tax reporting with respect to Forms 926, 8865, 8621, 5471, etc.
  • Analysis of debt and equity, income of a tax‑exempt client (UBTI), and...

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