Director, US Funds Tax in City of London

Description

Director, US Funds Tax

London

About Alvarez & Marsal

Alvarez & Marsal (A&M) is a global consulting firm with entrepreneurial, action and results-oriented professionals. We take a hands-on approach to solving our clients' problems and assisting them in reaching their potential. Our culture celebrates independent thinkers and doers who positively impact our clients and shape our industry. The collaborative environment and engaging work—guided by A&M's core values of Integrity, Quality, Objectivity, Fun, Personal Reward, and Inclusive Diversity—are why our people love working at A&M.

The Team

Alvarez and Marsal Tax’s U.S. Funds team is an exciting and unique opportunity. The team provides a broad range of U.S. tax compliance and reporting, as well as fund structuring and ad-hoc advisory services to European-based clients across many sectors in the Asset Management industry, such as Private Equity and Real Estate. The team is well placed to provide U.S. tax services, with a focus on international tax issues, to asset managers that have U.S. cross-border activity. A&M is seeking ambitious and enthusiastic top-performing individuals to join the growing business and team.

In today’s increasingly complex global tax environment, having international reach, a strong local presence and the right expertise is critical to the successful execution of all client tax affairs.

Responsibilities

• Lead complex U.S. tax advisory and reporting engagements across the private equity fund lifecycle, with responsibility for overall delivery, quality, and client service.
• Act as a senior point of contact for clients, providing practical and commercially focused advice on U.S. tax matters affecting fund structures, transactions, and cross-border investments.
• Build and deepen client relationships, identifying opportunities to expand A&M’s service offering and develop new areas of work.
• Lead U.S. tax workstreams on fund formations, acquisitions and disposals, restructurings, and other complex transactions.
• Take an active role in business development, including developing opportunities, preparing proposals and pitches, networking, and building relationships across the market.
• Work collaboratively with colleagues across practices and jurisdictions to identify opportunities and deliver integrated solutions to clients.
• Lead, coach, and develop team members, providing technical guidance and creating opportunities for junior colleagues to take on greater responsibility.
• Contribute to the continued growth and development of the U.S. Funds practice, including improving processes, sharing technical knowledge, and supporting recruitment and team initiatives.

Qualifications

• CPA or EA qualified.
• Significant experience advising private equity, alternative investment fund and/or asset management clients on U.S. tax matters.
• Strong understanding of U.S. fund tax reporting, including Forms 1065, Schedules K-1 and K-3, and international information reporting such as Forms 8865, 5471, 8858 and 926.
• Strong understanding of U.S. international tax matters relevant to cross-border fund structures, including CFC, PFIC and QEF considerations, entity classification and check-the-box elections, and the U.S. tax consequences of changes in entity classification.
• Experience advising on the U.S. tax aspects of fund formations, acquisitions, disposals, restructurings, continuation funds and other complex transactions.
• Strong knowledge of ECI, FIRPTA and U.S. withholding regimes applicable to funds and their investors, including Sections 1445 and 1446, along with the relevant reporting Forms 1042 and 1042-S.
• Strong understanding of U.S. tax considerations for U.S. taxable, U.S. tax-exempt and non-U.S. investors, including ECI, UBTI and the use of blocker structures.
• Experience with cross-border financing and investment structures, including debt/equity considerations, shareholder loans and interest deductibility under Sections 163(j) and 267(a).
• Strong knowledge of U.S. withholding and reporting requirements, including Forms 1042/1042-S and withholding considerations under Section 1446(f).
• Ability to research and analyze complex U.S. federal income tax issues and translate technical conclusions into practical, commercially focused advice.
• Proven ability to lead complex engagements, manage competing priorities and take ownership of senior client relationships.
• Excellent written and verbal communication skills.

The ideal candidates will be engaged, entrepreneurial, action-orientated, and hands-on. The ability to quickly establish, develop and enhance internal and client relationships will be key in the collaborative network we work in at A&M.

What can we offer you?

• Leadership: Growing EMEA leadership team and high-quality colleagues to work with in a fun and collegiate environment.
• An inclusive and diverse surrounding where employees are able to bring their full self to work, to feel that they belong and give them a voice and to ensure that voice is heard.
• Career development: A&M is rapidly expanding. The opportunities for internal career progression as A&M Tax grows is visible.
• Technical development: We will support your continuing professional development within this tax team through work opportunities and coaching from our experienced senior team.
• Remuneration: A&M offers a competitive salary and an excellent and genuinely performance related bonus scheme where individuals’ contribution to the team’s success is identified during the year.

Your journey at A&M

We recognize that our people are the driving force behind our success, which is why we prioritize an employee experience that fosters each person’s unique professional and personal development. Our robust performance development process promotes continuous learning, rewards your contributions, and fosters a culture of meritocracy. With top-notch training and on-the-job learning opportunities, you can acquire new skills and advance your career.

We prioritize your well-being, providing benefits and resources to support you on your personal journey. Our people consistently highlight the growth opportunities, our unique, entrepreneurial culture, and the fun we have together as their favorite aspects of working at A&M. The possibilities are endless for high-performing and passionate professionals. The possibilities are endless for high-performing and passionate professionals.

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