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Associate, Credit Funds Tax

New York

Credit Funds

Ref#: 2910

Date published: 3-Mar-2022

Associate, Credit Funds Tax

New York, NY 


About Fortress

Fortress Investment Group LLC is a leading, highly diversified global investment manager with approximately $54.2 billion of assets under management as of September 30, 2021. Founded in 1998, Fortress manages assets on behalf of over 1,750 institutional clients and private investors worldwide across a range of credit and real estate, private equity and permanent capital investment strategies. Investment performance is our cornerstone - we strive to generate strong risk adjusted returns for our investors over the long term. For additional information on Fortress, please visit www.fortress.com.


About the Position 

The Associate will work principally in a legal capacity as a member of the Credit Tax team at Fortress reporting to the Head of Tax and Structuring, Fortress Credit Funds. This position will be responsible for documentation and project management supporting the Credit Tax team. A tax background is not required but would help the successful candidate get up to speed more quickly. The individual will work closely with the attorneys in the Credit Tax structuring team, as well as members of the Credit Tax compliance team and others in various groups, including Accounting, Operations, and Investor Relations. 


Hours: Manageable and flexibility to work remotely.  


Responsibilities:

Drafting documentation ancillary to transactions and funds, generally post-closing

o Drafting LLC/partnership agreements for investment partnership subsidiaries of funds

o Drafting notes issued by corporations to their parent funds

o Revisions to LLC/partnership and other agreements to reflect changes in deal structures and/or law changes post-closing

o Drafting rescission agreements where transactions are rescinded after being initially signed

o Adding additional series to investment partnerships and series LLCs for new transactions that require “blocker” structures.

o Drafting plans of liquidation for blockers/LLC series and effect redemptions of investment partnership series held by those blockers/LLC series

Draft documentation to obtain treaty eligibility for deal entities

o Draft requests for UK treaty passports

o Draft requests for UK treaty clearance

o Providing UK treaty clearances and passports to borrowers where needed

o Maintain database of evidence of treaty eligibility where filing/treaty clearance not required

Maintaining a chart of all tax provisions in all fund documentation for use by team members in deal structuring

Maintaining a transfer pricing data base for interest rates on blocker notes

o Working with operations and real estate asset management teams to put together appropriate comparable transactions

o Working with outside counsel to write up transfer pricing documentation for all blocker notes.

Assist with investor onboarding for fund closes and LP transfers

o Review sub docs and W-8/W-9s

o Track issues and resolutions by investors

o Communicate with investors where needed

o Review assignment agreements for transfers

o Diligence “publicly traded partnership” issues for transfers

Maintain database of investor W-8/W-9s, CRS Self-certifications and other tax documentation

Review/comment on credit agreements for “offshore eligibility”/compliance with LSTA model provisions

Assist with annual FIN 48 documentation of uncertain tax positions

Other projects as assigned 


Required Qualifications/Experience:  

Bachelor’s degree and J.D. from an accredited college/law school.  

1 -3 years of relevant experience. At least a year of law firm experience preferred.  

Excellent organizational and legal writing skills required. 

Extremely strong attention to detail and verbal communication skills. 

Demonstrated flexibility to handle multiple projects in a fast-paced environment.

Self-starter, ability to work both independently and as a team player.  

Unquestionable integrity and ethics. 





Fortress Investment Group LLC collectively with its subsidiaries and operating affiliates is an equal opportunity employer and considers all applicants for employment without regard to race, religion, creed, color, sex, age, national origin, citizenship status, disability, genetic information, protected veteran status, marital status, sexual orientation, gender identity, or any other status protected by federal, state or local law.