PGIM - Vice President, Corporate Counsel (Tax) (Hybrid)

Job Classification

Corporate - Legal and Compliance

A GLOBAL FIRM WITH A DIVERSE & INCLUSIVE CULTURE

As the Global Asset Management business of Prudential, we’re always looking for ways to improve financial services. We’re passionate about making a meaningful impact - touching the lives of millions and solving financial challenges in an ever-changing world. We also believe talent is key to achieving our vision and are intentional about building a culture on respect and collaboration.

When you join PGIM, you’ll unlock a motivating and impactful career – all while growing your skills and advancing your profession at one of the world’s leading global asset managers! If you’re not afraid to think differently and challenge the status quo, come and be a part of a dedicated team that’s investing in your future by shaping tomorrow today. At PGIM, You Can!

PGIM is the global asset management business of Prudential Financial, Inc. and one of the world's leading investment managers. With approximately $1.5 trillion in assets under management, PGIM serves institutional and individual investors across public and private markets through a broad range of investment strategies, including fixed income, equities, real estate, private credit, multi-asset and alternative investments. Through investment funds, separately managed accounts and customized investment solutions, PGIM helps clients pursue their long-term investment objectives worldwide. PGIM's investment businesses combine deep market expertise, global reach and specialized capabilities to serve pension plans, sovereign wealth funds, insurance companies, financial institutions and individual investors across global markets.

We are seeking an experienced and commercially-minded Vice President, Corporate Counsel (Tax) tax attorney to advise PGIM’s private credit, real estate fund and client advisory businesses on U.S. and international tax matters, including cross-border fund structures and investments. The role also covers PGIM-related matters with tax implications for Prudential Financial as a corporation, including strategic investments and transfer pricing considerations among PGIM entities. This senior product and transaction tax role sits at the intersection of fund and investment structuring, product development, and investor requirements. The attorney will work closely with PGIM’s business and legal teams and with Prudential Financial’s tax team to provide practical tax advice and help bring new products and mandates to market.

The current employee work arrangement for this position is hybrid and requires your on-site presence on a reoccurring basis as determined by your business. Your manager will provide additional details relative to the specific number of days you are expected to be on-site.

What you can expect:

• Shape Fund Tax Structures and Bring Products to Market

• Partner with PGIM investment, product and legal teams, outside counsel, and Big Four firms on the tax design, launch and expansion of private credit, tax-aware strategies, asset-based finance and real estate funds.

• Design and evaluate U.S. and cross-border structures for U.S. taxable, tax-exempt and non-U.S. investors, including partnerships, REITs, feeders, parallel funds, blockers and other investment vehicles. Address withholding, treaty eligibility, permanent establishment risk and other international tax considerations.  Develop strategies to admit new investor types while protecting the tax position of existing investors.

• Review tax provisions and disclosures in offering documents, limited partnership agreements, side letters and other fund documentation, and align those provisions with the fund’s intended investments and investor base.

• Support the tax implementation of new products and mandates, translating structuring decisions into workable investment-review, documentation and operational processes.

• Advise on tax issues throughout a fund’s life, including review of proposed investments for effectively connected income (ECI) and unrelated business taxable income (UBTI) exposure, whether an investment should be held through a blocker, and audit.

• Advise on Investor Mandates and Investment Decisions

• Review tax provisions in investment management agreements and analyze investments and transactions for ECI, UBTI, withholding, treaty and investor-specific considerations.

• Advise on ECI exposure, season-and-sell arrangements, loan classification and related structuring questions.

• Serve as a tax resource for asset-based finance and separately managed account initiatives, including tax diligence and review of proposed investments.

• Participate in investor diligence meetings and question-and-answer processes, including as needed, explaining fund tax structures and expected after-tax returns to existing and prospective clients when needed.

• Coordinate tax opinions and technical reviews with outside tax counsel and other advisors to resolve significant tax questions.

• Advise on FATCA/CRS requirements coordinating with business teams, administrators and external advisors.  Provide guidance on investor tax documentation and withholding forms, including Forms W-8 and W-9, self-certifications and related remediation.

What you’ll need:

• Juris Doctor (JD) degree and active license to practice law in at least one U.S. jurisdiction.

• Typically 4-10 years of relevant tax-law experience, preferably involving investment funds, asset management, private credit or real estate.

• Deep knowledge of U.S. federal income tax rules applicable to private credit, real estate, fund partnerships, REITs, RICs, financial instruments and corporate transactions.

• Demonstrated expertise in international and cross-border tax matters, including withholding, treaty eligibility, permanent establishment risk and the ECI tax considerations affecting non-U.S investors.

• Experience advising on private credit and asset-based finance transactions, fund and investment-vehicle structuring, product launches and related transaction documents.

• Sound commercial judgment and the ability to analyze complex tax issues, evaluate structuring alternatives, quantify risk and translate technical requirements into clear, practical advice for legal, business and operations teams.

• Strong analytical, drafting and communication skills, with the ability to manage multiple priorities and work across business, legal, finance and operations teams.

• Experience working with and managing outside counsel and other tax advisors.

What will set you apart:

• LL.M. in Taxation.

• Experience at a global asset manager, investment firm, Big Four firm, or law firm with a substantial investment management advisory practice.

The attorney in this position is expected to be a hands-on asset management tax lawyer who can analyze transaction facts, identify the tax issues that drive outcomes, coordinate advisor input and provide practical answers to legal, business and operations teams. The role requires close collaboration with Prudential Financial’s tax team and for sound judgment in balancing technical tax requirements with product, investor and implementation needs.

PGIM welcomes all applicants, even if you don't meet every requirement. If your skills align with the role, we encourage you to apply.

At PGIM, you can:

Take charge of your career. We equip and empower our employees to expand their skills and experience by using powerful learning, gigs, and job opportunities. We offer a suite of services such as on demand resources and networking to propel your career forward.

We’re a global organization, full of outstandingly dedicated people who aren’t afraid to think differently, challenge the status quo and take sensible risks along the way. You will enjoy pushing boundaries as we build innovative technology that helps clients, customers and employees live their best lives. You will have access to leadership and learning opportunities and the resou