Director, Tax Controversy

What you'll do

• Lead U.S. federal tax audits and manage IRS examinations, negotiations, and settlements.
• Develop and execute audit defense strategies supported by technical documentation and data analytics.
• Manage the negotiation of Advance Pricing Agreements (APAs) and maintain documentation for uncertain tax positions.
• Provide strategic input on cross-border transactions, IP integration, and entity rationalization.
• Represent the company in discussions with tax authorities to negotiate favorable outcomes.
• Advise senior leadership on controversy risks, audit developments, and financial statement implications.
• Partner with Legal, Finance, and Treasury teams to implement tax-efficient global structures.
• Mentor and develop global team members while fostering a culture of technical excellence.

What we're looking for

• Bachelor’s degree in Accounting, Finance, or a related field.
• CPA, JD, or LLM in Taxation is strongly preferred.
• 10+ years of tax consulting, compliance, and reporting experience in Big 4 or U.S. multinational corporate tax departments.
• Proven success leading IRS tax audits and controversies.
• In-depth knowledge of U.S. international tax provisions and OECD developments like BEPS and Pillar Two.
• Experience with digital economy taxation, IP structuring, and transfer pricing.
• Strong analytical, negotiation, and communication skills to influence senior leadership and tax authorities.
• Experience managing teams and collaborating across global, matrixed organizations.