The role requires substantive experience advising on the U.S. federal income tax treatment of financial instruments and products.
Key areas of experience include advising investment funds on inbound U.S. tax issues from positions in debt, derivatives, and commodities (including ECI and "dealer" risk), as well as expertise in debt instruments (original issue discount, contingent payment, distressed debt, Section 1001), derivatives (Section 1256 contract rules), structured products, notional principal contracts, and hybrid instruments.
Experience should also cover constructive sale, straddle, and wash sale rules (Sections 1259, 1092, 1091), Section 1221 hedge identification rules, withholding tax issues (Sections 871(m), 1441, 1442) for cross-border financial products, and taxation of hedge funds, regulated investment companies, and other pooled investment vehicles holding financial instruments.
Preferred experience includes advising financial institutions, asset managers, trading firms, broker-dealers, or corporate treasury groups on new or novel financial products, including drafting or reviewing tax opinions, and familiarity with relevant IRS guidance, Treasury regulations, and case law governing financial instruments.
The role involves strong technical drafting skills for tax opinions, private letter ruling requests, and technical memoranda, and the ability to work directly with trading desks, structuring groups, or capital markets teams to analyze tax consequences and translate complex tax concepts for non-tax professionals.
Experience supervising and mentoring junior team members is preferred, with a demonstrated record of business development and client relationship management being a plus for special counsel candidates.

Fried, Frank, Harris, Shriver & Jacobson LLP

Senior Financial Products Tax Associate / Special Counsel

6+ PQE · October 14, 2026 (Today)

Fried, Frank, Harris, Shriver & Jacobson LLP

6+ PQE · October 14, 2026 (Today)

Salary

$225,000 - $435,000

Employment type

Full-time

Practice area

Tax · Capital Markets · Derivatives · Investment Funds

Locations

District of Columbia · New York City

Trusted recruiters

Work with a recruiter who has a real relationship with the hiring team and comes recommended by your peers.

Overview

The role requires substantive experience advising on the U.S. federal income tax treatment of financial instruments and products.
Key areas of experience include advising investment funds on inbound U.S. tax issues from positions in debt, derivatives, and commodities (including ECI and "dealer" risk), as well as expertise in debt instruments (original issue discount, contingent payment, distressed debt, Section 1001), derivatives (Section 1256 contract rules), structured products, notional principal contracts, and hybrid instruments.
Experience should also cover constructive sale, straddle, and wash sale rules (Sections 1259, 1092, 1091), Section 1221 hedge identification rules, withholding tax issues (Sections 871(m), 1441, 1442) for cross-border financial products, and taxation of hedge funds, regulated investment companies, and other pooled investment vehicles holding financial instruments.
Preferred experience includes advising financial institutions, asset managers, trading firms, broker-dealers, or corporate treasury groups on new or novel financial products, including drafting or reviewing tax opinions, and familiarity with relevant IRS guidance, Treasury regulations, and case law governing financial instruments.
The role involves strong technical drafting skills for tax opinions, private letter ruling requests, and technical memoranda, and the ability to work directly with trading desks, structuring groups, or capital markets teams to analyze tax consequences and translate complex tax concepts for non-tax professionals.
Experience supervising and mentoring junior team members is preferred, with a demonstrated record of business development and client relationship management being a plus for special counsel candidates.

Trusted recruiters

Top recruiter for this opening
Bryson Malcolm
Mosaic Search Partners
Bryson Malcolm
Mosaic Search Partners
Jonathan Trebble-Greening joined Fried Frank’s District of Columbia office in the Investment Funds group.
Bryson is what everyone wants in a recruiter. From his first message to his interview preparation to his handling of offers, Bryson provided detailed information about every law firm (including detailed information about each interviewer + testimonials where available) and how each offer compared to what was going on in the market. He never hid the ball and was really helpful at getting interviews scheduled around my packed big law calendar. He is particularly well-versed in minority representation at firms which is an added bonus if that impacts you, and I know it is something that I always take into consideration when looking at a workplace. I’d use his services again - he’s really top-notch!

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Last updated: October 14, 2026

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