"Tax Attorney (Associate General Counsel)"

Job Description Summary

The Division of Finance and the Office of General Counsel of the University of Pennsylvania seek a full-time highly skilled and strategically minded tax attorney with a proven track record advising complex tax-exempt organizations, particularly in the higher education and health system sectors. The ideal candidate will bring deep technical knowledge of Subchapter F, UBTI, partnerships, and investment taxation, and will be comfortable navigating the nuanced regulatory frameworks applicable to mission-driven institutions with sophisticated investment portfolios.

Serves as a senior legal advisor, delivers strategic counsel on complex matters involving institutional operations, compliance, partnerships and alliances. Leads the development and oversight of legal frameworks that govern contracts and transactions and ensures alignment with federal and state law as well as University policy. Manages outside counsel and mitigates legal risk through proactive guidance and training.

Job Responsibilities

• Advise tax-exempt entities-including academic medical centers, universities, hospitals, and foundations-on compliance with federal and state tax laws.
• Provide counsel on investment tax matters, including private equity, hedge funds, joint ventures, complex partnership structures, and foreign investments (e.g., PFICs, CFCs, and FATCA implications).
• Address tax implications of unrelated business income (UBI) and UBTI planning strategies, including siloing rules and allocation of expenses.
• Interpret and apply IRS guidance relating to tax-exempt organizations, including private letter rulings, audit defense, and legislative developments.
• Work cross-functionally with investment officers, finance, legal, and operational teams to support compliant investment and business operations.
• Assist with tax due diligence and structuring mergers and acquisitions and affiliation transactions in the higher education and healthcare sectors.
• Draft and review legal memoranda, client alerts, opinion letters, and other technical documentation.
• Stay current with tax law changes affecting tax-exempt organizations and advise clients accordingly.
• Provide legal support related to innovative activities, development of new services and innovative technology, and arrangements with commercial entities.
• Provide advice to senior management, staff and employees on a wide range of legal issues impacting development activities, regulatory issues and administrative policies.
• Negotiate, review and draft agreements and other documentation for such transactions, perform due diligence activities and prepare governing body resolutions.
• Manage and oversee the work of outside attorneys dealing with transactional activities and related issues.
• Other duties and responsibilities as assigned.

Core Responsibilities & Duties:

Tax Planning & Compliance:

• Developing and implementing tax-efficient strategies to minimize the institution's tax burden.
• Advising on compliance with federal, state, and local tax laws and regulations relevant to educational institutions, including those related to tax-exempt status.
• Staying up to date on changes in tax laws, regulations, and rulings.

Advisory & Consultation:

• Providing expert legal advice to senior administrators and other departments on various tax-related issues, such as payroll taxes, benefits, grants, and endowments.
• Analyzing the tax implications of various university operations and initiatives.

Tax Disputes & Litigation:

• Representing the institution in tax disputes, audits, and negotiations with tax authorities (federal, state and local).
• Drafting and reviewing legal documents related to tax matters.
• Litigating or assisting outside counsel with tax disputes in court.

Contract Review & Negotiation:

• Reviewing contracts, leases, and other legal documents to identify and address tax implications.
• Negotiating agreements related to tax controversies or audits.

Risk Management:

• Identifying and assessing tax-related risks and implementing strategies to minimize potential legal and financial exposure.
• Providing training to faculty and staff on relevant tax matters.

Required Qualifications

• Graduate from a recognized college or university and graduation from an ABA accredited law school with a J.D. degree.
• Must be admitted and in good standing in Pennsylvania or other state bar prior to starting the position; admission to the Pennsylvania bar expected within one year of hire date. Admission to New Jersey bar desired but not required.
• Minimum 5 years of relevant experience in a law firm, Big 4 Accounting Firm, the public sector (e.g. the Internal Revenue Service) or in-house legal department.
• Significant experience advising tax-exempt organizations on complex tax issues, particularly in higher education and healthcare.
• Demonstrated proficiency in investment tax, including fund structures and cross-border compliance.
• Strategic mindset and strong business acumen to support University goals while mitigating risk.
• Exceptional communication skills and ability to translate complex tax concepts to non-tax stakeholders.

Preferred Qualifications

• LL.M. in Taxation or prior/current licensure as Certified Public Accountant.
• Admission to U.S. Tax Court
• Prior experience with IRS audits or ruling requests.
• Familiarity with state-level nonprofit taxation, property tax exemptions, or PILOT arrangements.

Job Location

Philadelphia, Pennsylvania

Department / School

Division of Finance

Pay Range

$150,000.00 - $225,000.00 Annual Rate