US Tax Lawyer – Fund Transactions

Responsibilities

• Ensure U.S. tax compliance for the management of private equity funds, taking into account risk, operational, and tax considerations
• Continuously analyze U.S. tax legislation and assess its impact on portfolio investments and investors
• Review distribution provisions in fund agreements and determine distribution allocations for investors
• Analyze international tax rules for PFICs and CFCs and oversee U.S. tax reporting obligations (Forms 926, 8865, 8621, 5471, etc.)
• Advise on characterization of debt and equity, unrelated business taxable income (UBTI) for tax‑exempt clients, and other tax matters relevant to private equity funds
• Evaluate clients' investments for U.S. tax implications
• Provide investment‑related advice on the selection of U.S. tax structures
• Act as a single point of contact for tax‑related queries from internal and external stakeholders
• Monitor guidance a...