Tax Senior Associate / Special Counsel (Financial Products Focus) at Fried Frank

The role

Fried Frank is seeking a Tax Senior Associate or Special Counsel with a focus on financial products to join their New York or Washington D.C. office. This role requires 6+ years of relevant tax experience, with a specialization in advising on the U.S. federal income tax treatment of financial instruments and products.

What we're looking for

6+ years of relevant tax experience at a law firm or accounting firm

Substantive experience advising on the U.S. federal income tax treatment of financial instruments and products

Experience advising investment funds on inbound U.S. tax issues arising from positions in debt instruments, derivatives, and/or commodities

Experience with debt instruments, including original issue discount (OID), contingent payment debt instruments, distressed debt issues, and modifications/exchanges under Section 1001

Experience with derivatives (swaps, options, forwards, futures) and the Section 1256 contract rules

Experience with structured products, notional principal contracts, and hybrid instruments

Experience with constructive sale, straddle, and wash sale rules (Sections 1259, 1092, 1091)

Experience with the Section 1221 hedge identification rules

Experience with withholding tax issues under Sections 871(m), 1441, and 1442 for cross-border financial products

Experience with taxation of hedge funds, regulated investment companies (RICs), and other pooled investment vehicles holding financial instruments

Licensed to practice law or otherwise eligible for admission in the jurisdiction where they are applying

Experience advising financial institutions, asset managers, trading firms, broker-dealers, or corporate treasury groups on the tax treatment of new or novel financial products, including drafting or reviewing tax opinions· nice to have

Familiarity with relevant IRS guidance, Treasury regulations, and case law governing the character, timing, and source of income from financial instruments· nice to have

Strong technical drafting skills, including experience preparing tax opinions, private letter ruling requests, and technical memoranda· nice to have

Ability to work directly with trading desks, structuring groups, or capital markets teams to analyze the tax consequences of proposed transactions and new products· nice to have

Excellent analytical, written, and verbal communication skills, with the ability to translate complex tax concepts for non-tax professionals· nice to have

Exceptional collegiality and professionalism with colleagues, clients, and counterparts at other professional service firms· nice to have

Experience supervising and mentoring junior team members· nice to have

Demonstrated record of business development and client relationship management (for special counsel candidates)· nice to have

Tax Senior Associate / Special Counsel (Financial Products Focus)

The role

What we're looking for

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