Tax Counsel - Controversies & SALT

Tax Controversy Management

Serve as the primary legal advocate for managing all aspects of U.S. federal, state, and foreign tax controversies, audits, and disputes.
Lead and manage state and local tax audits across multiple jurisdictions, including correspondence, negotiations, and advocacy before state and local tax authorities.
Develop and execute audit defense strategies, including preparation of responses to information document requests (IDRs), notices of proposed adjustments, protests, and administrative appeals.
Assess litigation risk and make recommendations to senior management on settlement versus litigation strategies.
Coordinate and manage outside counsel and tax advisors engaged in tax controversy matters.
Support IRS examination and appeals proceedings, including preparation of protest letters and participation in appeals conferences.
Assist with managing foreign tax controversies in coordination with international tax colleagues and outside counsel.
Maintain a comprehensive tracking system for all open tax audits, disputes, and litigation matters across all jurisdictions.
Coordinate with the tax compliance and accounting teams to ensure audit findings and settlements are properly reflected in tax returns and financial statements, including uncertain tax positions under ASC 740-10 State and Local Tax ("SALT").

Advisory

Develop and maintain deep expertise in state and local tax laws, regulations, rulings, and case law across jurisdictions relevant to IBKR.
Advise on SALT implications of business activities and transactions, including nexus analysis, apportionment, and allocation issues specific to financial services and technology companies.
Monitor legislative, regulatory, and judicial developments in SALT and assess their impact on IBKR’s tax positions and compliance obligations.
Identify and evaluate SALT planning opportunities to minimize IBKR’s overall state and local tax burden.
Partner with the tax compliance team to provide technical guidance on state and local tax return positions.

Legal Research, Documentation & Collaboration

Perform legal research on federal, state, and foreign tax controversy issues and deliver well-reasoned legal conclusions.
Draft legal memoranda, technical position papers, and protest letters to document legal conclusions and tax positions.
Partner with the broader Global Tax Team on tax controversy implications of business activities and transactions.
Collaborate with Legal, Compliance, and Accounting teams on matters that intersect with tax controversy issues.
Assist with research, development, and integration of new tax technologies, including controversy management tools and automation.
Support Internal Audit/Risk Reviews and work on special projects as needed.