Senior Legal Counsel – Private Client Tax, Global Mobility

This is a fully remote position, open to applicants in Ukraine.

📋 Description

• Provide expert guidance to high-net-worth individuals on cross-border tax strategies, relocation, wealth management, and personal tax compliance.

• Execute yearly tax planning that encompasses tax residency, income sources, dividends, asset sales, and relocation considerations.

• Develop income receipt frameworks, including dividends, fund distributions, payments, and loans.

• Evaluate the tax implications of personal transactions related to real estate, vehicles, art, and business interests.

• Secure and uphold special tax regimes for new residents and non-domiciled individuals.

• Strategize pre-immigration and exit procedures, covering residence alterations, day counts, split-year considerations, exit taxes, and treaty tie-breakers.

• Formulate relocation plans in collaboration with immigration service providers and oversee permit or program processes.

• Manage transitions from temporary statuses to permanent residency and citizenship.

• Oversee family reunification processes, parents’ residency, and children’s immigration statuses.

• Monitor immigration renewals, absence limits, and necessary registrations.

• Assess personal holding and investment structures, including CFC, GAAR, and anti-avoidance considerations.

• Provide counsel on succession planning and philanthropic entities.

• Select and supervise local tax and immigration advisors, ensuring control over scope, deadlines, fees, and uniformity across different jurisdictions.

⛳️ Requirements

• Proficient in determining a client’s tax residency and planning residence changes utilizing day-count and centre-of-vital-interests tests, split-year rules, exit-tax provisions, and treaty tie-breakers.

• Skilled in structuring individual income across various jurisdictions, including dividends, capital gains, fund distributions, and related-party loans, while calculating after-tax results.

• Proven experience in securing and maintaining special tax regimes for new residents and non-doms, such as Cyprus non-domiciliary status, Malta, Polish lump-sum arrangements, UK FIG, or similar frameworks.

• Ability to evaluate and manage CFC, GAAR, and anti-avoidance risks, as well as planning the dissolution of dormant entities without incurring tax liabilities.

• Expertise in analyzing personal structures, including foundations, trusts, and holding companies, with a focus on beneficiary and distribution taxation.

• Competence in designing global mobility relocation pathways and overseeing immigration service providers.

• Experienced in managing personal tax compliance across multiple jurisdictions, including tax returns, CFC and foreign asset filings, rulings, and implications related to CRS/FATCA, as well as narratives concerning source of wealth and funds.

• Ability to articulate options, risks, and recommendations fluently in both Ukrainian and English.

• Possession of a legal or tax qualification.

🏝️ Benefits

• 28 business days of paid leave.

• Flexible working hours and the option to work remotely.

• Medical insurance and mental health support.

• Financial coverage for courses and training opportunities.

• English language classes and speaking clubs.

• Access to an internal library and educational events.

• Participation in corporate gatherings and team-building activities.