Advise diverse clients on structuring domestic and cross-border investments across various asset classes, private investment offerings, FIRPTA, trust and fiduciary matters, mergers and acquisitions, and corporate and partnership re-organizations.
Draft and negotiate related contracts, investment documents, and trust and fiduciary instruments, alongside preparing memoranda and opinions on complex US tax issues.
Required experience areas include real estate taxation (including FIRPTA, REITs, qualified opportunity zones, and 1031 like-kind exchanges), estate planning and holding structures, private equity (including fund formation, carried interest structures, and M&A), partnership tax and joint ventures, energy (including tax credit monetization transactions), and family office structuring.
The role involves collaborating with colleagues across different practice groups and countries, and requires an aptitude for learning and adapting to new, developing areas of tax law lacking formal guidance. An LLM in taxation is not required but may be favorably considered.

Mid-Level Private Capital Tax Associate

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