International Tax Counsel

2 weeks ago

Armonk, United States IBM Computing Full time

IBM International Tax Counsel in Armonk, New York Introduction 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, let's 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 About Business Unit The IBM Finance organization is responsible for driving enterprise performance and transformation. We are the financial stewards of IBM, delivering IBM's financial strategy, developing new business models, and mitigating enterprise risk. Your Life @ IBM In a world where technology never stands still, we understand that dedication to our clients' success, innovation that matters, and trust and personal responsibility in all our relationships live in what we do as IBMers as we strive to be the catalyst that makes the world work better. Are you ready to be an IBMer? About IBM IBM's greatest invention is the IBMer. We believe that through the application of intelligence, reason, and science, we can improve business, society, and the human condition, bringing the power of an open hybrid cloud and AI strategy to life for our clients and partners around the world. Location Statement IBM offers a competitive and comprehensive benefits program. Eligible employees may have access to healthcare benefits, financial programs, generous paid time off, training and educational resources, and diverse employee resource groups. Being You @ IBM IBM is committed to creating a diverse environment and is proud to be an equal-opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, gender, gender identity or expression, sexual orientation, national origin, caste, genetics, pregnancy, disability, neurodivergence, age, veteran status, or other characteristics. #J-18808-Ljbffr

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