This position will work strategically with the tax team and outside tax firms to facilitate the preparation of investor K-1s (which include footnotes related to foreign filings and pro forma foreign forms) and PFIC statements. In addition, this role will spearhead various other projects that come up throughout the year such as quarterly taxable income estimates, UK passport applications and tracking, FDAP and ECI withholding, ongoing tax analysis of foreign loans and equity investments, and exits and restructures of foreign investments. Strong project management skills will be necessary to ensure ensure that day-to-day responsibilities are moving while also ensuring foreign tax compliance is executed accurately and timely.

Responsibilities:

• Oversee and manage the Firm’s US and foreign tax compliance for all foreign funds / entities and related entities. This includes (1) privately held investment partnerships and funds, (2) various subsidiaries of these funds including numerous foreign regarded and disregarded entities and (3) QII calculations and FDAP withholding for a publicly traded BDC / RIC and four privately held BDC / RICs
• Work in a cross-functional environment and serve as a bridge between Fund Accounting, Investor Communications, Technology Solutions and Direct Lending; requires strong communication and diplomacy skills
• Oversee and review the work of the Tax Accountants to create complete, accurate tax work paper packages for the outside tax firms that prepare K-1s, PFIC statements and foreign tax returns / forms. Ensure tax deliverables are user-friendly for the company’s investors and owners
• Answer questions posed by Executive Management on items related to foreign tax reporting and withholding
• Review Forms 926, 5471, 8621, 8858, 8865 and other international forms prepared by outside tax preparer
• Review and coordinate with Investor Communications Team on foreign tax related questions from investors
• Work independently and with external advisors to apply for, obtain and maintain valid UK passports for the BDCs and Private Funds in addition to any other relevant jurisdiction passports to eliminate / reduce withholding
• Review and provide input on notice responses related to foreign tax items and help coordinate any IRS or foreign country audit exams
• Review and be the project manager for foreign information reporting (e.g., 1042’s) including agent / lender withholding and internal tax forms for foreign entities (e.g., W-8’s, withholding statements, etc.)
• Document ASC 740 (FIN 48) analysis for foreign entities that undergo financial statement audits and assist the Fund Accounting Team and external auditors in the preparation and review of tax provisions and tax footnotes
• Work with external consultants and Investor Communications Team to review entity classifications, GIINs and global filing requirements under FATCA and Global CRS
• Collaborate with Direct Lending and Strategic Tax Teams to review and assist with the tax structure review of all proposed foreign equity investments, exits and restructures. Assess whether foreign stock and partnership investments require foreign tax filings
• Manage subordinates including reviewing their work, scheduling their workload, driving projects to completion, and supporting their career development
• Create exhibits related to foreign tax compliance for the monthly tax meetings with Executive Management

Qualifications:

• Bachelor’s degree in Accounting + a Masters in Tax
• CPA certification
• 7-10 years of proven tax experience in the financial services industry (mix of public accounting and industry experience is a plus)
• Strong existing foreign tax knowledge of partnership taxation, RICs (Regulated Investment Companies), C-corps, US based and non-US based investment vehicles, foreign reporting requirements and withholding requirements
• Strong knowledge of US Tax Treaties including double tax treaty positions and treaty benefits
• An understanding of the tax issues associated with debt investments such as OID, AMD, non-accrual status and sig mods
• Strong written and verbal communication skills
• Results-oriented, strong project management skills including the ability to drive people and projects to completion
• Comfort with and prior experience in a fast-paced and high-growth environment – excellent organizational skills with the ability to handle numerous projects at a time and prioritize as appropriate
• Highly meticulous, detail and process oriented
• Driven with a passion for tax
• Takes initiative with a strong emphasis on a team-orientated mentality
• Prior supervisory experience and aptitude/desire to oversee people and lead/motivate other
  

Posted On: Friday, April 14, 2023