Senior Associate - Tax Funds - London

The Alternative Investment Funds tax team is the market leading provider of tax advice for top-tier global fund managers. Having worked on many of the major European fund raises in the last couple of years, the team is centre of excellence in fund structuring. The team has a truly global reach, combining experience of local tax issues relevant to fund managers and the ability to co-ordinate global projects. Sitting alongside the London Deals tax team, the team maintains an integrated approach along with the deal structuring team.The Alternative Investment Funds tax team delivers a range of services including fund structuring, fund reporting and executive tax services. Our team works with Private Equity, Infrastructure, Credit and Real Estate fund managers throughout the lifecycle of a fund. We provide advice on the following

• legal form and jurisdiction of the fund vehicle

• specific investor requirements in relation to the fund and associated structuring advice
• the location of the fund manager and advisor and associated implications for the sponsor and key executives
• carried interest structuring
• co-investment structures for cross-border teams
• VAT implications for the general partners and the fund
• incentivisation of key executives

We also provide ongoing support in relation to the fund for both the sponsor, as well as the executives. This includes advising on the tax consequences of the anticipated value and returns for management and carry holders. Further, we also provide comprehensive fund reporting services for sponsors.
We are seeking to recruit a new team member into the Alternative Investment Funds sub-team within the London Deals tax team. This role will encompass a mixture of tax advisory projects, with a strong focus on private equity funds and fund managers, including assisting with complex computational matters. The role provides an excellent opportunity to understand how private equity houses raise and structure new funds, how fund structures interact with deals, how private equity houses are diversifying into other forms of asset management, and how compensation is structured for alternative fund managers. We would expect the individual to be involved with the following types of work

• Giving fund structuring advice to private equity houses on the structuring of new funds which will involve reviewing legal documentation, producing structure papers and/or memos to explain the structuring and liaising with PwC overseas offices if tax advice in other jurisdictions is required.
• Dealing with ad-hoc queries in relation to funds tax questions, examples include HMRC enquiries, PAYE queries, VAT, valuations, etc.
• Helping clients compute tax liabilities (individual and corporate) arising on their investments in complex onshore and offshore private fund structures.
Requirements

• ACA and/or CTA qualified (or at least exam qualified).
• Have an interest in asset management, specifically in private equity. Knowledge of asset management tax is desirable but not essential.
• The role will require a knowledge of income tax, capital gains tax and corporate tax.
• A knowledge of partnership tax is desirable but not essential.
• Enthusiasm to expand tax technical skills, as the role requires analysis of a number of different areas of legislation, both corporate and personal.
• Strong project management skills, as projects will often involve liaising with numerous stakeholders.
• Good attention to detail and strong writing skills.
• The ability to work accurately under time pressure and manage multiple on-going projects.

Tax
We help organisations and the people who run them answer the big business questions. How should we raise finance? Where should we be based? How should we reward our people? With some 3,300 experts whose expertise covers every conceivable area of taxation, we're one of the UK's leading tax practices.
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