Tax Controversy Advisory Counsel
IBM
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This listing doesn't post a salary. Most similar roles pay $137,762–$225,000.
Based on 240 similar postings.
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IBM is a US-based global technology company providing hybrid cloud, AI, consulting, enterprise software, and IT infrastructure products and services.
IBM currently has 506 open roles on FindRole.
Listed pay typically runs $174,632–$197,165 across 5 roles with salary data.
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At a glance
M&A Tax Counsel joins the corporate tax department to support Corporate Development and Business Development groups regarding acquisitions, dispositions, and joint venture opportunities. This role involves managing the entire deal lifecycle from initial opportunity identification through execution and integration. The successful candidate will calculate tax consequences for financial modeling, prepare tax sections of diligence reports, develop structuring plans, and collaborate with external counsel to draft contract provisions. Key technical competencies include cross-border M&A, Subchapter C including section 367, TCJA, Subpart F income, the US foreign tax credit system, and Pillar 2 rules. The role requires expertise in tax research and legal writing while communicating complex concepts to senior business leaders, finance teams, and legal departments to ensure transactions are properly recorded in books and records.
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