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Tax Advisor - Attorney The candidate will assist the Americas Tax Advisory team in executing its responsibilities in evaluating and advising the Wealth Management and Asset Management business divisions. Will support in the evaluation of new business initiatives and complex transactions, monitoring adherence to the Bank's Tax Sensitive Transaction policy and other tax risk management functions. Become involved in tax advisory matters involving Human Resource and other compensation-related tax matters and issues involving global permanent establishment risk management. Interact directly with internal clients and the ability to identify, research and resolve tax issues with minimal supervision. Should have J.D. degree and ideally L.L.M. degree in Taxation. Must have 2+ years of work experience in a law firm, accounting firm or the tax department in a financial institution. Must have strong research capabilities and writing skills. Must have basic knowledge in all, and expertise in at least three, of the following areas would be desired: (i) Hedge and private equity funds, (ii) Subchapters C, K and M, (iii) Financial products, including notional principal contracts, structured notes and other derivatives, (iv) IRAs, (v) Cross border lending transactions including withholding and conduit issues (vi) Information reporting and withholding related to TEFRA, FATCA, cost basis and 871(m), (vii) IRS and state audits and (viii) Nonqualified employee compensation programs and fringe benefits.
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