Director - Tax Planning / Tax M&A

About the Opportunity

The Director, Tax Planning/Tax M&A will provide strategic and technical leadership on U.S. federal income tax planning matters, with a primary focus on mergers, acquisitions, divestitures, restructurings, separations, and other corporate transactions. This role will serve as a senior tax technical resource for the Tax organization and cross-functional business partners, helping to design, evaluate, document, and execute tax-efficient structures that align with business objectives, manage risk, and support sustainable tax outcomes. This is an onsite position with 1 day of remote work. U.S. based candidates open to relocating will be considered.

Responsibilities

• Lead tax planning analysis and execution for significant corporate transactions, including mergers, acquisitions, divestitures, joint ventures, restructurings, separations, spin-offs, and other strategic initiatives.
• Provide deep U.S. federal income tax technical guidance, with particular emphasis on Subchapter C of the Internal Revenue Code, including corporate reorganizations, distributions, liquidations, Section 355 transactions, Section 368 reorganizations, Section 351 contributions, and related consolidated return considerations.
• Partner with Legal, Treasury, Controllership, Corporate Development, FP&A, business teams, and external advisors to evaluate transaction alternatives, identify risks and opportunities, and deliver practical, business-oriented solutions.
• Prepare, review, and manage high-quality technical tax memoranda, transaction step plans, risk assessments, ruling requests, and other documentation supporting tax planning positions.
• Support tax due diligence, structuring, modeling, documentation, and implementation activities for domestic and cross-border transactions.
• Collaborate with Tax Accounting & Reporting to assess the financial statement impact of tax planning positions, including ASC 740 considerations, uncertain tax positions, valuation allowance implications, and tax disclosure matters.
• Coordinate with Tax Compliance to ensure planning positions are accurately and consistently reflected in tax returns, workpapers, elections, statements, and related filings.
• Monitor and analyze legislative, regulatory, IRS, Treasury, and judicial developments affecting corporate tax planning and transaction structuring; communicate impacts and recommended actions to senior Tax leadership.
• Manage external law firm and accounting firm advisors, including scoping, budgeting, work product review, and integration of advisor input into internal decision-making.
• Build trusted relationships with Finance, Legal, Treasury, and business leadership by translating complex tax technical matters into clear, actionable guidance.
• Support audit defense by maintaining audit-ready documentation and assisting with technical responses to tax authority inquiries related to planning transactions.
• Contribute to the development of internal tax planning processes, controls, governance standards, and knowledge-sharing practices.

Requirements

• Juris Doctor degree required; LL.M. in Taxation preferred.
• 5+ years of experience in a major law firm or comparable environment advising on complex corporate transactions, including mergers, acquisitions, divestitures, restructurings, reorganizations, and related tax planning matters.
• Strong technical foundation in U.S. federal income tax planning, mergers and acquisitions, and corporate transaction structuring.
• Deep technical knowledge of Subchapter C of the Internal Revenue Code and related Treasury Regulations, IRS guidance, and case law.
• Demonstrated ability to analyze complex tax issues, develop technically sound positions, and communicate practical recommendations to senior stakeholders.
• Experience drafting and reviewing tax technical memoranda, transaction step plans, due diligence reports, ruling requests, opinions, and implementation documentation.
• Strong project management skills with the ability to manage multiple transaction workstreams, deadlines, and stakeholders in a fast-paced environment.
• Excellent written and verbal communication skills, including the ability to explain sophisticated tax concepts clearly to non-tax audiences.
• High degree of professional judgment, attention to detail, integrity, and ownership.

Preferred Experience

• Experience advising multinational corporations or public company clients on transaction structuring, separations, spin-offs, or post-transaction integration.
• Exposure to international tax, consolidated return, partnership, financing, or transfer pricing considerations relevant to corporate transactions.
• Experience working with cross-functional deal teams, including Legal, Treasury, Corporate Development, Accounting, and external advisors.
• Public company or in-house corporate tax experience is a plus.