International Tax Counsel

Your Role and Responsibilities

IBM is a leader in worldwide transformation and just the place to further define and develop your career in Tax. Our dedicated teams of business professionals give our clients more than solutions – we ask, “what else is possible?”.

As a member of our IBM Tax team, you’ll have the opportunity to grow your expertise with a market leader, while exploring and connecting with virtually every part of IBM, in over 160 countries.

When you join IBM, you join a culture of openness, collaboration, and trust. Join us and experience a place where you can co-create your learning and opportunities. A place where teamwork and unique ideas are treasured. A place where you can bring innovation to life.

Skills

• Strong tax technical skills in areas such as: Subchapter C, including section 367 NCTI, Subpart F, and other international rules
• Dividends and E&P mechanics, including related foreign exchange rules
• The US foreign tax credit system
• Taxation of financial transactions
• Pillar 2 rules

Preferred Education

A Master's Degree is required.

Technical and Professional Expertise

• Between 5-10 years of experience with:
• Working with clients or senior business leaders, finance and legal teams to clearly articulate tax concepts
• Characterizing, analyzing, and computing tax consequences of corporate structuring transactions
• Modeling the financial impact of proposed financial transactions
• Working with external counsel to draft and review relevant contract provisions
• Developing structuring plans to guide execution in a manner that meets the business and other functional teams' needs
• Working with tax accounting to ensure that transactions are properly recorded in the books and records

Preferred Technical and Professional Experience

• At least 8 years’ experience in technical tax (subchapter C, including section 367, subpart F income, the foreign tax credit system)
• At least 8 years’ experience in tax research
• At least 8 years’ experience in tax and legal writing
• JD or CPA