Senior Attorney - Tax Specialist (Part Time) at Federal Reserve Bank in New York City, NY

Position Description: Senior Attorney - Tax Specialist

Part Time - 3 Days a week

The Federal Reserve Bank of New York is seeking a part-time tax attorney for our Legal Group with a specialization in tax matters related to supervisory policy initiatives and regulation (see examples below). In addition to responding to tax questions from the Bank's supervisory team, the tax attorney will be expected to provide legal advice concerning employment and benefits-related tax matters as well as tax matters concerning the operations of the Bank. In tax matters that are outside the scope of the tax attorney's expertise, he/she will be expected to oversee the work of approved outside counsel.

Areas of responsibility include:

    Tax matters relating to supervisory and regulatory policy (required experience):
    Analyze and understand the tax implications of supervisory policy initiatives and regulations including but not limited to:
    Tax effects of capital, leverage, and liquidity regulations and requirements
    Tax consequences of long term incentive compensation structures
    Tax implications of financial institution structured products including execution, legal, accounting and reputational risk
    Identifying the underlying determinant of tax driven transactions

Tax matters relating to employment and benefits (preferred experience):

    Advise the Bank on tax matters relating to employment and benefit issues including but not limited to:
    Taxation of telecommuters
    Taxation of travelers or other employees who work at locations other than head office
    Taxation of employees on secondment outside the United States and non-U.S. employees on secondment at the Bank
    Taxation issues related to fringe benefits
    Various 409A issues
    State law tax issues

Tax matters relating to Bank operations (preferred experience):

    Advise the Bank on tax matters relating to Bank operations including but not limited to:
    All aspects of tax reporting, filing and withholding with regard to Bank account holders (both domestic and foreign financial institutions) and vendors
    All aspects of tax reporting, filing and withholding with regard to Bank transactions (with both domestic and foreign entities), including repurchase and reverse repurchase transactions
    The Foreign Account Tax Compliance Act (FATCA) and Treasury regulations implementing FATCA
    Real estate tax questions (assessments and protests)
    Sales tax collection by owner/property manager from tenant for services

Required experience:

    A minimum of 5 years of experience as a tax attorney in a non-litigation context with a focus on the types of matters identified above under "Tax matters relating to supervisory and regulatory policy".
    Admitted to practice law in the state of New York;
    Experience representing clients before taxing authorities including the Internal Revenue Service;
    Strong client service skills;
    Excellent writing and oral communication skills; and
    Superior organizational skills with an ability to handle prioritize and complete numerous projects simultaneously.

Desired experience:

    Experience advising clients on tax matters related to employees and operations;
    Demonstrated ability to provide oversight for and collaborate with outside counsel to ensure high quality legal services and adherence to retainer agreements; and
    In-house experience, particularly within a large, complex organization.

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