Senior Associate Attorney

5 days ago


New York, New York, United States Davis Polk Full time
Senior Associate Attorney

At Davis Polk, we are seeking a highly skilled Senior Associate Attorney to join our team. As a Senior Associate Attorney, you will play a key role in providing legal advice and representation to clients on a full range of deal-related tax questions and tax structuring involving corporate reorganizations, mergers and acquisitions, securities offerings, and restructuring transactions.

Key Responsibilities:
  • Provide legal advice and representation to clients on a full range of deal-related tax questions and tax structuring.
  • Draft and negotiate contracts for corporate reorganizations and other taxable and tax-free mergers and acquisitions.
  • Negotiate tax structures and draft tax structuring step plans for restructuring transactions, corporate reorganizations, and other taxable and tax-free mergers and acquisitions.
  • Review, draft, and negotiate documents and contracts with respect to restructuring transactions, including bankruptcy plans, disclosures, transaction support agreements, and debtor-in-possession credit agreements.
  • Prepare legal memoranda summarizing the application of tax law regarding tax-free reorganizations, tax issues relating to restructuring, tax issues relating to structured financial products, international tax regime, and withholding regime.
  • Review and submit private letter ruling requests to the Internal Revenue Service (IRS) on behalf of clients and prepare presentations.
  • Submit comment letters to Treasury on behalf of clients lobbying for tax reform related regulations.
Requirements:
  • Juris Doctor, Master of Laws, or foreign academic equivalent.
  • Three years of legal experience involving corporate tax legal matters, including mergers and acquisitions, private equity funds, restructuring transactions, structured financial products, and capital.
  • Three years of legal experience in using Excel spreadsheets for various tax analysis related to debt instruments.
  • Three years of legal experience in drafting and reviewing tax disclosures for capital market transactions, including straight debt, contingent payment debt instruments, common stock, preferred stock, and convertible notes.
  • Three years of legal experience in providing legal advice and representation to clients on a full range of deal-related tax questions involving capital markets transactions, restructuring transactions, and credit agreements.
  • Three years of legal experience in reviewing and negotiating stock and assets acquisition agreements and ancillary agreements for mergers and acquisitions.
  • Three years of legal experience in reviewing pricing supplements for offerings of structured financial products under shelf registrations.
  • Three years of legal experience in drafting tax memorandums and opinions with respect to a full range of deal-related tax issues.
Salary:

$260,000.00 to $365,000.00 per year



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