Tax Controversy Advisory Counsel

What you'll do

• Lead all aspects of IRS audits including developing strategies and managing Information Document Requests (IDRs).
• Serve as the primary point of contact with IRS teams to ensure consistent engagement across audit workstreams.
• Defend company tax positions regarding transfer pricing, cross-border transactions, and other international issues.
• Manage dispute resolutions and escalations by drafting protests and engaging with IRS Appeals or litigation support.
• Coordinate with internal finance, accounting, business teams, and external advisors to align on tax matters.
• Advise senior leadership on audit developments, risk assessments, and potential strategic outcomes.

What we're looking for

• Master's Degree (preferred).
• Deep expertise in IRS tax controversy and audit experience, including managing IDRs and litigation support.
• Deep technical expertise in U.S. and international tax matters, specifically transfer pricing and cross-border transactions.
• Strong leadership skills to coordinate cross-functional teams and manage external advisors.
• Ability to communicate audit strategy, risk assessments, and outcomes to senior leadership.