Mid-Level Associate, Tax

Cleary Gottlieb Steen & Hamilton LLP seeks an Associate (mid-level) in New York, NY to research and analyze legal issues, in particular issues pertaining to U.S. federal income taxation, in connection with United States and international issues. Requires J.D., LL.M. or equivalent and two years of experience as an Associate or related occupation.

Must include 2 years of experience in each of the following:

• Structuring private equity investments (e.g., analyzing the use of alternative investment entities, parallel funds and corporate blockers) to ensure the most efficient economic and regulatory structure for U.S. federal income tax purposes
• Drafting U.S. federal income tax disclosure statements for all common capital markets transactions, such as debt offerings and IPOs, for both U.S. and non-U.S. issuers
• Structuring M&A transactions (e.g., internal reorganizations, asset sales) to ensure that U.S. and non-U.S. clients achieve the most favorable available U.S. federal income tax treatment of the transaction
• Negotiating and drafting U.S. federal income tax terms of private equity, debt financing and M&A transactions, as well as over-the-counter capital markets transactions such as share repurchase agreements and swaps
• Performing quantitative analysis and structuring, such as change-in-yield analysis and pricing analysis, for complex debt transactions such as exchange offers, consent solicitations and real estate mortgage investment conduits
• Negotiating and drafting U.S. federal income tax terms and disclosures in chapter 11 restructuring proceedings.

The base salary for associate positions is $215,000 to $415,000/ year, depending upon class year. Must be admitted to practice law in the State of New York.