Tax Controversy Advisory / Counsel

About the role

IBM Finance & Operations is the backbone of IBM’s transformation, driving efficiency, transparency, and smart decision-making across the business. Our teams provide the insight and discipline that guide strategy, ensure financial strength, and enable IBM to invest in innovation and growth. Working in Finance & Operations means combining analytical skills with collaboration and curiosity. You’ll partner with colleagues across functions and geographies, using data, technology, and process excellence to create solutions that improve performance and deliver measurable impact.

IBM is seeking an experienced Tax Controversy Attorney/Analyst to join its Global Tax Controversy team in Armonk, New York. This role will lead and manage IRS examinations and disputes involving complex U.S. tax matters. The successful candidate will serve as IBM’s primary liaison with IRS examination teams and will coordinate the company’s overall audit strategy.

Responsibilities

• Lead all aspects of IRS audits, including developing audit strategies, managing Information Document Requests (IDRs), and driving issue resolution in collaboration with IRS teams.
• Serve as the primary point of contact with the IRS to ensure consistent, disciplined engagement and alignment across multiple audit workstreams.
• Defend the company’s tax positions on matters involving transfer pricing, cross-border transactions, and other international tax issues.
• Manage dispute resolution and escalations, including drafting protests, engaging with IRS Appeals, and supporting litigation as needed.
• Coordinate with cross-functional stakeholders, including finance, accounting, business teams, and external advisors.
• Advise senior leadership on audit developments, risk assessments, potential outcomes, and strategic considerations.

Requirements

• Deep expertise in IRS tax controversy and audit experience, including leading complex IRS examinations, managing IDRs, negotiating issue resolution, and working with IRS Appeals and litigation support.
• Deep technical expertise in U.S. and international tax matters, particularly transfer pricing, cross-border transactions, and other complex corporate tax issues.
• Strong leadership and stakeholder management skills, with the ability to coordinate cross-functional teams, manage external advisors, and communicate audit strategy, risk, and outcomes to senior leadership.

Qualifications

Preferred Education: Master's Degree