Tax Counsel – Asset Based Finance

Sixth Street•New York, NY

2d•$225,000 - $250,000•Onsite

About The Position

This is a full-time role based in New York. As Tax Counsel – Asset Based Finance, you will be a part of the global Tax Team, leading the tax and structuring workstreams for Asset Based Finance (ABF) transactions and platform. The Tax Team is responsible for structuring investments to maintain capital efficiency, manage tax risk and comply with global tax reporting obligations. As a member of this team, you will be responsible for managing the day-to-day transactional tax matters related to ABF transactions working integrally with the ABF investment team, Core Platform, and external service providers, reporting to Sixth Street’s Director of Tax and Deputy Director of Tax.

Requirements

Candidates should possess specific focus or understanding of tax rules for ABF, structured finance and securitizations with a minimum of 6 years tax experience at a reputable law firm or a nationally recognized accounting firm. (In-house candidates from comparable roles will also be considered)
Candidates should have broad familiarity with complex financial transactions and tax structures for financings, securitizations, joint ventures and other complex financial transactions
Experience working across asset classes including residential mortgages, consumer (e.g., credit cards, student loans, auto loans, etc.) commercial, real estate, and others.
An in-depth understanding of the ECI rules (e.g., loan origination and dealer considerations) relating to complex financial transactions
Candidates should possess strong tax technical abilities and demonstrate thoughtful judgment in interpreting tax concepts to real-world matters and practical implications
Ability to multi-task and maintain composure in a high-volume environment
Ability to communicate complex tax concepts into commercial terms for teams
Ability to think strategically about process and procedure implementation as part of a dynamic business
The candidate should be a licensed attorney.

Nice To Haves

Ideal candidates will possess experience with alternative investment funds and nuances of broad investor considerations

Responsibilities

Assist with negotiating and overseeing tax aspects of ABF investments, which may include credit facilities; broadly syndicated debt offerings and private placements; complex platform equity investments; residential and commercial mortgage-backed investments; whole-loan sales; asset pools and forward flow arrangements; securitizations for various asset classes including consumer, specialty and commercial lending; joint ventures; and various other types of asset-based finance transactions
Advise on tax and structure considerations applicable to asset-based finance transactions, including the characterization of debt instruments, loan origination considerations, ECI considerations relating to committed and uncommitted forward flows, dealer considerations, REIT and REMIC qualifications and grantor trust/partnership classification of securitization vehicles
Develop and document processes and procedures related to Sixth Street’s preferred practices and tax positions; leverage technology tools and AI to systematize processes and guidelines
Assistance with tax considerations related to managing existing ABF investments, including exiting investments, loan modifications, refinancings, restructurings and workouts
Review and advise on tax considerations in transaction documentation for ABF investments, including credit agreements, indentures, joint venture and partnership agreements and purchase and forward flow agreements
Work with external advisors on tax due diligence and help teams assess tax risks
Drive deal execution, including coordination with the ABF investment team and Sixth Street Core on ABF structure implementation, entity formation, and transaction documentation and work through operational and accounting nuances of transactions
Understand implications of ABF transactions on Sixth Street’s fund and investor covenants and obligations
Work closely with Sixth Street’s Tax Reporting team to ensure tax reporting is considered and reporting reflects intended tax and structure for all ABF investments
Manage outside counsel relationships and partner with outside counsel in connection with the foregoing; be a steward of investor capital
Monitor changes to tax reporting laws, rules and regulations applicable to existing and future Sixth Street funds and help assess the potential impact on Sixth Street’s ABF transactions
Translate complicated tax concepts into commercial language and actionable items to the ABF investment team
Work closely with stakeholders across the ABF business and Sixth Street including investment professionals, the Core team, including members of the Legal team, in connection with the foregoing.