International Tax Counsel



Posted on Friday, January 12, 2024
At IBM, work is more than a job – it’s a calling: To build. To design. To code. To consult. To think along with clients and sell. To make markets. To invent. To collaborate. Not just to do something better, but to attempt things you’ve never thought possible. Are you ready to lead in this new era of technology and solve some of the world’s most challenging problems? If so, lets talk.

Your Role and Responsibilities
We are seeking an experienced candidate with very strong U.S. international tax technical and project management skills to join IBM’s corporate tax department as International Tax Counsel. The selected candidate will perform significant U.S. tax technical research, writing, and analysis, and will work closely with various business units, country management and advisors to create and implement strategies to address business issues. In addition, the candidate will provide on-going monitoring of, and commentary on, applicable tax legislation and regulations; and provide timely
information to tax operations in order to facilitate financial statement preparation and tax compliance.

Required Technical and Professional Expertise
The ideal candidate should also have 6-10 years of experience:
• Working with a diverse and global team
• Working in an agile way, including employing a growth mindset
• Working with senior business leaders to clearly articulate tax concepts
• Calculating the tax consequences of a transaction for use in financial modeling
• Reviewing financial statements and valuation reports
• Developing structuring plans to guide execution in a manner that meets business needs

Preferred Technical and Professional Expertise
The ideal candidate should have strong tax technical skills in areas such as:
• US tax reform legislation and guidance (TCJA)
• U.S. tax research, writing, and analysis
• Subchapter C/cross border M&A, including section 367
• Subpart F income
• OECD Pillar 2 rules
• The U.S. foreign tax credit system, including FTC basketing and expense apportionment rules
• Familiarity with transfer pricing and partnership rules