Key responsibilities are expected to oversee and coordination the following:
Partner-Level Tax Compliance and Planning
Assist partners in managing their quarterly and annual installment estimated payments, taking into consideration the firm’s financial forecasts and safe harbor rules, distributions, partner-specific realization events, with a view to minimize the impact to partner cash flows
Determine the impact of taxable income allocations from funds and the impact of material book-tax differences, non-recourse liabilities in a given period and the impact on each partner’s partnership basis including issues around distributions in excess of basis. Assist partners with understanding each year’s tax allocations.
Assist partners with other planning or structuring around specific issues, or personal tax planning
For the international partners coordinate the appropriate tax withholding and coordinate any Napier-level structuring that may be beneficial
U.S. Management Company Tax
Assist in the transition to the new tax preparers who are primary responsible for the firm’s compliance program
Implement internal tax policies and procedures to ensure tax compliance and review
Review the firm’s tax allocations and ensure appropriate allocation methodologies are in place, given the firm’s economic activity and compensation plans
Review and assist in determining strategy around book-to-tax adjustments, specifically around material items such as intangible depreciable assets
Assist in determining the appropriate strategies to deal with phantom income issues, specifically around multi-year or back-ended crystallizations
Assist the corporate controller in the preparation of the ASC 740 analysis and deferred tax analysis for the purposes of financial reporting
Manage the GP entities’ tax compliance programs and assist with analysis around the admission of new partners
Project the impact of current year events on the management company and the funds; determine which funds if any may need to have additional work done around year-end to isolate the impact of significant realization activity
Coordinate the completion of any informational reporting as well as 1099 reporting, FBAR/FinCEN, etc.
Manage the state and local tax filing and estimate process with the external tax preparers
Assist in developing the process and procedures to track investor accounts, legal entities and fund domiciles for the purposes of revenue apportionment
Other International Operations
Review the compliance process relating to filing corporate tax returns in the UK
Assist in determine the appropriate cross-border implications of carried interest grants for U.S. funds with UK employee-participants
Review the compliance process relating to filing corporate tax returns in Switzerland
Fund Tax Compliance
Prepare and manage workflows and processes around domestic and foreign tax compliance for the fund entities, in collaboration with external tax preparer including to ensure timeliness and accuracy of reporting
Determine appropriate filing requirements, including where corporate returns are needed, vs. disregarded entities
Ensure partner allocations are consistent with the economics of each transaction
Work with internal teams to streamline information flows, processes, special reporting, investor questions and issues.
Prepare tax investment/fund structure charts and manage legal entity listing along with legal team
Assist in structuring and implementing various investment structures
Research & coordinate tax issues related to the Funds and special purpose vehicles.
Review and maintain withholding documentation and implement reporting for FATCA, CRS, etc.
Assist in technology projects to bring in house final tax allocations for reporting purposes
Monitor compliance with tax provisions in fund partnership agreements and side letters, specifically as it relates to minimization of UBTI/ECI, special allocations, and distribution waterfalls; liaise with council as needed to support conclusions
Develop a framework around the use of leverage
Involved in the tax compliance process and elections made by underlying portfolio entities as needed or applicable
Assist with other projects such as the impact of loan origination on fund taxable income and investor returns, trader funds vs. investor funds, etc.
Track the basis of fund investor accounts to determine when certain funds may become cash taxable and impact on withholding
Review fund level distributions to ensure a consistent policy around tax distributions and withholding
Prepare workpapers and memorandums supporting calculations and conclusions regarding payments, withholdings, and proposed structures
Understand intricacies of performance waterfalls and management fees from fund level through to management company and partner distribution
At least 7-10 years of related experience in a public accounting/tax firm, private equity, credit/hedge fund, venture capital or investment management experience is required.
Self-starter who will take initiative and can work independently and proactively to identify and resolve issues.
Ability to prioritize and complete projects on a timely basis
Possess strong communication and organizational skills
Ability to work well in a fast-paced/high-pressure team environment
About Napier Park Global Capital
Napier Park is a global alternative asset management platform with approximately $12 billion in assets under management. The 100% employee controlled firm offers a broad range of investment products to select institutional investors.