International Tax Counsel

About the role

IBM is a leader in worldwide transformation and offers a unique opportunity to further define and develop your career in Tax. As a member of the IBM Tax team, you’ll advise Corporate Tax, Treasury, and Legal Departments on capital structuring, financial operations, and corporate restructurings. You will identify and implement opportunities that drive IBM’s tax policies and strategies while collaborating with teams across over 160 countries. IBM fosters a culture of openness, collaboration, and trust, where teamwork and innovation thrive.

Responsibilities

• Advise on tax implications of capital structuring, financial operations, and corporate restructurings.
• Identify and implement tax strategies to support IBM’s global tax policies.
• Collaborate with Corporate Tax, Treasury, and Legal Departments to articulate tax concepts clearly.
• Characterize, analyze, and compute tax consequences of corporate structuring transactions.
• Model the financial impact of proposed financial transactions.
• Work with external counsel to draft and review contract provisions.
• Develop structuring plans to align with business and functional team needs.
• Ensure transactions are properly recorded in books and records with tax accounting.

Requirements

• Strong tax technical skills in:
  • Subchapter C, including section 367 NCTI and Subpart F.
  • Dividends and E&P mechanics, including foreign exchange rules.
  • The US foreign tax credit system.
  • Taxation of financial transactions.
  • Pillar 2 rules.
• 5-10 years of experience working with clients or senior business leaders, finance, and legal teams to articulate tax concepts.
• Experience modeling financial impacts of proposed transactions.
• Experience developing structuring plans to guide execution.

Qualifications

• Master’s Degree (preferred).
• At least 8 years of experience in technical tax (Subchapter C, section 367, Subpart F income, foreign tax credit system).
• At least 8 years of experience in tax research and legal writing.
• JD or CPA (preferred).