Mid-Level Associate Attorney - Corporate Tax/Complex Transactional

Strategic Tax Counsel | Mid-Level Associate – Corporate Transactions 💰

§ Practice Area: Domestic and International Tax Planning / Investment Fund Structuring

§ Location: Silicon Valley, CA (Flexibility for nearby San Francisco, CA residency)

§ Salary: $225,000 to $435,000 Base Salary (Plus comprehensive bonus and benefits structure)

§ Schedule: Full-time, Direct-Hire, Minimum 1,850 hours annual billed target.

The Firm

Our distinguished client is a Global Top 25 law firm, highly revered for its expansive global network and sophisticated client roster, which includes major Fortune 500 corporations, leading private equity sponsors, and institutional investors. The Tax practice is consistently recognized with Tier 1 national rankings for its deep expertise in complex business planning and transactional structuring.

This firm is known for fostering a collegial environment while providing unmatched technical resources, offering associates the opportunity to shape the financial architecture of significant domestic and cross-border deals. They champion an integrated approach, ensuring legal counsel is strategically aligned with paramount commercial objectives. This is an exceptional platform for an ambitious tax attorney seeking exposure to the highest caliber of transactional work in the technology and private investment sectors.

Duties

The incoming Mid-Level Tax Associate will function as a pivotal advisor to the firm’s Corporate and Private Investment Funds practices, ensuring optimal tax efficiency and compliance across high-value business combinations and structuring activities. This is a highly technical role demanding mastery of the federal income tax consequences of complex commercial undertakings.

Core responsibilities include:

⨖ Architecting Tax-Efficient Structures for mergers, acquisitions, dispositions, and joint ventures involving both public and private operating companies.

⨖ Drafting and Negotiating all tax-specific provisions within transaction documents, including Stock Purchase Agreements (SPAs), merger agreements, and representations and warranties insurance policies.

⨖ Advising Private Investment Funds (PIFs) on the tax implications of fund formation, carried interest planning, and the tax consequences of inbound and outbound investments by limited partners (LPs).

⨖ Providing expert counsel on the tax treatment of complex financial instruments, alternative investment vehicles, and corporate reorganizations under Subchapters C and K of the Internal Revenue Code.

⨖ Conducting and synthesizing in-depth tax due diligence to quantify and mitigate potential tax liabilities and risks inherent in target companies.

Qualifications:

Candidates must possess an established track record and the technical expertise required to immediately contribute to a highly sophisticated practice.

⨖ Juris Doctor (J.D.) from an ABA-accredited law school with a distinguished academic record.

⨖ Active Bar Membership in the state of California, or qualification to waive in promptly.

⨖ Three (3) to Six (6) Years of substantive, direct experience in transactional tax law at a globally recognized law firm.

⨖ Demonstrated technical mastery of partnership taxation (Subchapter K) and corporate tax (Subchapter C) as applied to M&A and fund formation.

⨖ Superior drafting, negotiation, and communication skills required for interaction with senior partners, clients, and opposing counsel.

Skills:

The following qualifications are highly desirable and would significantly enhance an applicant's candidacy:

⨖ An L.L.M. in Taxation from a top-tier program.

⨖ Specific experience counseling clients on the tax considerations of REITs, UPREITs, or other real estate fund structures.

⨖ Familiarity with basic principles of international tax compliance and planning as they affect cross-border transactions (e.g., GILTI, Subpart F).

⨖ Proven ability to manage complex, multi-faceted projects independently, including supervising junior attorneys and managing client deliverables.

!Notice¡

This a job advertisement on behalf of our client and does not reflect the full job description for the role. Any qualified candidates are encouraged to apply. You will need to provide law school transcripts, a writing sample or deal sheets, and a cover letter in order to be considered for this role. This posting does not constitute an offer of employment and the listed compensation details may vary by state or experience and will be discussed thoroughly during interview phase.