PGIM - Vice President, Corporate Counsel (Tax) (Hybrid)

Prudential Financial•Newark, NJ

4d•$208,400 - $312,600•Hybrid

About The Position

PGIM is seeking an experienced, commercially minded tax attorney to advise its private credit, real estate fund, and client advisory businesses on U.S. and international tax matters, including cross-border fund structures and investments. The role also addresses PGIM-related tax matters for Prudential Financial as a corporation, including strategic investments and transfer pricing among PGIM entities. This senior product and transaction tax position sits at the intersection of fund and investment structuring, product development, and investor requirements. The attorney will work closely with PGIM business and legal teams and Prudential Financial’s tax team to provide practical advice and help bring new products and mandates to market. The role involves tax design and launch of funds and strategies, structuring for different investor types, review of fund and investment documents, advice on investor mandates and proposed investments, and coordination with outside counsel and other tax advisors. The position is hybrid, with recurring on-site presence determined by the business.

Requirements

Juris Doctor (JD) degree and an active license to practice law in at least one U.S. jurisdiction.
Typically 4–10 years of relevant tax-law experience, preferably involving investment funds, asset management, private credit, or real estate.
Deep knowledge of U.S. federal income tax rules applicable to private credit, real estate, fund partnerships, REITs, RICs, financial instruments, and corporate transactions.
Demonstrated expertise in international and cross-border tax matters, including withholding, treaty eligibility, permanent establishment risk, and ECI considerations affecting non-U.S. investors.
Experience advising on private credit and asset-based finance transactions, fund and investment-vehicle structuring, product launches, and related transaction documents.
Sound commercial judgment and ability to analyze complex tax issues, evaluate structuring alternatives, quantify risk, and translate technical requirements into clear, practical advice.
Strong analytical, drafting, and communication skills.
Ability to manage multiple priorities and work across business, legal, finance, and operations teams.
Experience working with and managing outside counsel and other tax advisors.

Nice To Haves

LL.M. in Taxation.
Experience at a global asset manager, investment firm, Big Four firm, or law firm with a substantial investment management advisory practice.

Responsibilities

Partner with investment, product, and legal teams, outside counsel, and Big Four firms on the tax design, launch, and expansion of private credit, tax-aware strategies, asset-based finance, and real estate funds.
Design and evaluate U.S. and cross-border structures for U.S. taxable, tax-exempt, and non-U.S. investors, including partnerships, REITs, feeders, parallel funds, blockers, and other investment vehicles.
Address withholding, treaty eligibility, permanent establishment risk, and other international tax considerations, and develop strategies to admit new investor types while protecting existing investors’ tax positions.
Review tax provisions and disclosures in offering documents, limited partnership agreements, side letters, and other fund documentation, ensuring alignment with intended investments and investor base.
Support tax implementation of new products and mandates by translating structuring decisions into investment-review, documentation, and operational processes.
Advise on tax issues over a fund’s life, including proposed investments’ ECI and UBTI exposure, whether investments should be held through blockers, and audit matters.
Review tax provisions in investment management agreements and analyze investments and transactions for ECI, UBTI, withholding, treaty, and investor-specific considerations.
Advise on ECI exposure, season-and-sell arrangements, loan classification, and related structuring questions.
Serve as a tax resource for asset-based finance and separately managed account initiatives, including tax diligence and review of proposed investments.
Participate in investor diligence meetings and Q&A processes, explaining fund tax structures and expected after-tax returns to existing and prospective clients as needed.
Coordinate tax opinions and technical reviews with outside tax counsel and other advisors to resolve significant tax questions.
Advise on FATCA/CRS requirements in coordination with business teams, administrators, and external advisors.
Guide investor tax documentation and withholding forms, including Forms W-8 and W-9, self-certifications, and related remediation.
Work closely with Prudential Financial’s tax team and provide practical advice to legal, business, and operations teams.

Benefits

Market-competitive base salary and yearly bonus potential at every level.
Medical, dental, vision, life, and disability insurance.
Paid Time Off (PTO) and leaves of absence, including parental and military leave.
401(k) plan with company match up to 4%.
Company-funded pension plan.
Wellness Programs, including up to $1,600 per year for reimbursement of items purchased to support personal wellbeing needs.
Work/Life Resources covering parenting, housing, senior care, finances, pets, legal matters, education, emotional and mental health, and career development.
Education Benefit for approved traditional college enrollment and many accredited certificate programs.
Employee Stock Purchase Plan, allowing shares to be purchased at 85% of the lower of the beginning or ending purchase-period price.
Learning, networking, and career-development resources and opportunities.