Tax Attorney (Associate General Counsel)

University Overview

The University of Pennsylvania, the largest private employer in Philadelphia, is a world-renowned leader in education, research, and innovation. This historic, Ivy League school consistently ranks among the top 10 universities in the annual U.S. News & World Report survey. Penn has 12 highly-regarded schools that provide opportunities for undergraduate, graduate and continuing education, all influenced by Penn’s distinctive interdisciplinary approach to scholarship and learning. As an employer Penn has been ranked nationally on many occasions with the most recent award from Forbes who named Penn one of America’s Best Large Employers in 2023.

Penn offers a unique working environment within the city of Philadelphia. The University is situated on a beautiful urban campus, with easy access to a range of educational, cultural, and recreational activities. With its historical significance and landmarks, lively cultural offerings, and wide variety of atmospheres, Philadelphia is the perfect place to call home for work and play.

The University offers a competitive benefits package that includes excellent healthcare and tuition benefits for employees and their families, generous retirement benefits, a wide variety of professional development opportunities, supportive work and family benefits, a wealth of health and wellness programs and resources, and much more.

Posted Job Title

Tax Attorney (Associate General Counsel)

Job Profile Title

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 Description

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 prep