Tax Counsel

Pagaya InvestmentsNew York, New YorkFull TimeRemote

About The Position

Pagaya is a leading next-generation asset management firm founded in 2015. Combining advanced technology and financial expertise, we use artificial intelligence and state-of-the-art algorithms to uncover exceptional, low-risk high-yield opportunities in alternative credit for investors. Pagaya actively invests in US consumer credit assets.

The Pagaya team is comprised of over 150 professionals in New York and Tel Aviv with expertise in artificial intelligence, data rich alternative assets and asset management. The team manages over $3 billion in assets on behalf of institutional investors around the world.

Pagaya just completed its Series D financing of over $100M led by a prominent sovereign wealth fund.

 


Role Description:

As Tax Counsel, you will provide the highest quality advice and counsel to all parts of the business. We are looking for a smart, motivated, self-starter to join our growing global legal team in a rapidly growing company.

The ideal candidate is a business-minded lawyer who is focused on working with business teams to review tax aspects of new and established classes of asset backed securities, managing tax-related inquiries from a variety of the firm’s businesses across established and emerging markets.

This is an excellent opportunity to join a highly visible and growing global organization operating in a dynamic environment. Consequently, this role requires an energetic, enthusiastic and driven professional.

To be successful in our Tax Counsel role, we’re looking for someone who is passionate about business growth. We want a candidate who is excited by the challenge of working in a legally complex global fintech company and who welcomes the dynamic environment that comes with a growing company. This role will engage with all levels of employees and management, so social and communication skills are vital to strong working relationships.

The role reports to the General Counsel & Chief Compliance Officer (based in New York) and will be located in New York.

 


Key Responsibilities:

All aspects of US and international tax planning, consulting and compliance related to:

  • Drafting technical memorandums and documentation related to worldwide tax positions
  • Tax-related analysis and the development and implementation of plans related to inbound and outbound investments, mergers, restructurings, cross-border transactions, acquisitions, capital markets transactions and other special projects
  • Coordinating and effectively communicating with outside tax counsel, accounting firms, and internal stakeholders to ensure appropriate tax positions, risk controls, and compliance
  • Negotiating tax-related provisions in all agreements, including in side letters and other documentation with counterparties/clients/fund investors
  • Reviewing proposed legislation to determine impact on Pagaya, drafting proposed language, and coordinating with State Tax Government Relations on monitoring and responding to tax legislation
  • Managing international tax compliance, including but not limited to preparation, review and filing of relevant tax returns, undertaking and reviewing relevant tax calculations, maintaining documentation related to tax attributes, and providing guidance related to tax matters, including FBAR and FATCA
  • Managing US and local country international tax accounting & provision requirements, statutory and US GAAP. This includes coordinating and supporting (1) local country tax managers with provisions, deferred analysis, tax account reconciliations as well as (2) the US tax team for US GAAP-ASC 740 requirements. Follow SOX controls as it relates to International Tax. Analyze US and Non-US tax impacts of international transactions to determine impact on global taxes. Manage review and documentation for FIN48 and FAS 5 reporting requirement
  • Managing transfer pricing, BEPS reporting, related party agreements, and related party transaction either directly or through managing third party providers, including transfer pricing reviews/updates, local country reporting, and APA agreements as applicable. Manage the implementation of BEPS, CBC and related reporting requirements and monitor and address new requirements
  • Assisting with Business Advisory for international tax by maintaining effective relationships with Treasury, Finance, Accounting, Legal, Business Operations, and HR in order to advise on tax implications of cash flows, loans, repatriation, business models and planning, operations, and other special projects
  • Managing IRS international audits and assist local country managers in local audits
  • Assisting in preparation of the firm’s financial statements
  • Performing other duties and functions as assigned

Requirements

  • The ideal candidate will have 7+ years of international tax experience preferably in a law firm, in-house with multinational corporations or in public accounting. Financial Services experience preferred
  • JD and LLM preferred, MST or equivalent education also considered
  • CPA or JD, and in each case qualified in the United States (preferably NY or CA), is required
  • Extensive knowledge of corporate, business and individual tax issues
  • Significant experience with inbound and outbound international tax planning and compliance and transfer pricing
  • Good understanding of consumer credit assets, asset-backed securities and capital markets transactions, including an understanding of the industry and a working knowledge of direct competitors’ products and services
  • Native/Fluent English (written and spoken)
  • Proficient in the use of Microsoft Office Suite, specifically Word, Excel and PowerPoint
  • Experience utilizing RIA, BNA, Lexis Nexis and/or other tax research platforms,
  • Exceptional client service skills
  • Ability to work independently and master multiple tasks in a fast-paced environment
  • Work additional hours and travel as needed
  • Candidates should be prepared to meet challenging company requirements, provide value added services and should possess strong communication (both oral and written), interpersonal and analytical skills
  • Excellent judgment and initiative in developing creative, practical and effective solutions, using a business-first approach
Salary
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