M&A Tax Counsel

IBM

Confirmed live yesterday High trust
Hybrid

Quick summary

Work type
Hybrid
Location
Armonk, NY
Posted
14 days ago
Freshness
Confirmed live yesterday

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Salary context

How this pay compares to similar roles

Similar $181k
$127k most similar roles pay here $235k

This listing doesn't post a salary. Most similar roles pay $137,762–$225,000.

Based on 240 similar postings.

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About IBM

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

TL;DR · M&A Tax Counsel

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.

What you'll do

  • Advise Corporate Development and Business Development groups on acquisitions, dispositions, and joint venture opportunities.
  • Manage the full deal lifecycle from initial opportunity identification through execution and integration.
  • Calculate tax consequences of deals for use in financial modeling.
  • Prepare the tax section of due diligence reports.
  • Collaborate with external counsel to draft relevant contract provisions.
  • Develop structuring plans to guide transaction execution based on business and functional needs.
  • Coordinate with tax accounting to ensure transactions are properly recorded in books and records.
  • Provide technical expertise on cross-border M&A, Subchapter C, TCJA, and Pillar 2 rules.

What we're looking for

  • Candidates must possess a Bachelor's Degree, with a Master's Degree preferred.
  • Applicants must have the ability to work without current or future visa sponsorship.
  • The role requires 5-10 years of experience communicating tax concepts to senior business leaders and legal teams.
  • Experience is required in calculating deal consequences for financial modeling and preparing due diligence reports.
  • Candidates should have experience drafting contract provisions with external counsel and developing structuring plans.
  • Preferred candidates should have at least 8 years of experience in technical tax, research, and writing.
  • Preference is given to candidates licensed in Law or Accounting (CPA).
  • Technical expertise is required in cross-border M&A, Subchapter C, TCJA, Subpart F, foreign tax credits, and Pillar 2 rules.

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