Attorney, Tax

(New York, NY) Represent publ. & priv. co’s, fin. inst.,
PE firms, other inv. funds in conn. w/ tax issues arising from complex bus.
transact. in cross-border & dom. contexts, incl. M&A, reorgs, JVs, fund
formations & investments, debt & eq. financings, sec. offerings,
securitizations, financial products, restructuring transact. Review &
assess proposed transact. structures & terms from tax perspective. Negotiate,
prepare, revise tax-related provisions in transact. docs. Prepare, review,
revise tax opinions.  Analyze tax issues
under applicable laws and regs, incl. tax fungibility of debt instruments,
passive foreign inv. co. status of non-U.S. companies in cap. mkts. transact. $365,000
per year. Req’mts: JD or foreign equiv., NY Bar, 3 yrs of exp. in position or 3
years of alternate occupational exp. performing complex corporate transactional
tax advisory legal duties. In lieu of a JD or foreign equiv., an LLM or foreign
equiv. is acceptable. Email resume/ref’s to Kendyl.Ryan@lw.com, referencing
position TAX2. Latham & Watkins LLP.