International Tax Counsel at IBM

595984BR

Introduction

At IBM, work is more than a job - it's a calling: To build. To design. To code. To consult. To think along with clients and sell. To make markets. To invent. To collaborate. Not just to do something better, but to attempt things you've never thought possible. Are you ready to lead in this new era of technology and solve some of the world's most challenging problems? If so, lets talk.

Your Role and Responsibilities

We are seeking an experienced candidate with very strong U.S. tax technical and project management skills to join IBM's corporate tax department as International Tax Counsel. The selected candidate will perform significant U.S. tax technical research, writing, and analysis, and will work closely with various business units, country management and advisors to create and implement strategies to address business issues. In addition, the candidate will provide on-going monitoring of, and commentary on, applicable tax legislation and regulations; and provide timely information to tax operations in order to facilitate financial statement preparation and tax compliance.

The ideal candidate should have strong technical skills in areas such as:
• US tax reform legislation and guidance (TCJA)
• U.S. tax research, writing, and analysis
• Subchapter C, including section 367
• Subpart F income
• The U.S. foreign tax credit system, including FTC basketing, recent Final FTC regulations and expense apportionment rules
• Familiarity with transfer pricing and partnership rules

The ideal candidate should also have 6+ years of experience:
• Working with a diverse and global team
• Working in an agile way, including employing a growth mindset
• Working with senior business leaders, finance, treasury, and legal teams to clearly articulate tax concepts
• Calculating the tax consequences of a transaction for use in financial modeling
• Reviewing financial statements and valuation reports
• Developing structuring plans to guide execution in a manner that meets the business and other functional team’s needs

Working with tax accounting to ensure that transactions are properly recorded in the books and records; and collaborating within IBM Tax to ensure that all projects are accurately reported on IBM's tax returns and are properly documented for audit

Required Technical and Professional Expertise
• 6+ years’ experience in technical tax
• 6+ years’ experience in tax research
• 6+ years' experience in tax and legal writing
• Licensed in Law or Accounting (CPA)

Preferred Technical And Professional Expertise
• Master’s Degree in Law
• 10+ years’ experience in technical tax.
• 10+ years’ experience in tax research.
• 10+ years’ experience in tax and legal writing

About Business Unit

The IBM Finance organization is responsible for driving enterprise performance and transformation. We are the financial stewards of IBM, delivering IBM’s financial strategy, developing new business models, and mitigating enterprise risk. Do you have a passion for creating business value? Join our team in accounting, financial planning, pricing, business controls, tax, treasury, business development (acquisitions & divestitures), and global financing.

This job requires you to provide your COVID-19 vaccination status with supporting documentation, where legally permissible.

Your Life @ IBM

Are you craving to learn more? Prepared to solve some of the world's most unique challenges? And ready to shape the future for millions of people? If so, then it's time to join us, express your individuality, unleash your curiosity and discover new possibilities.

Every IBMer, and potential ones like yourself, has a voice, carves their own path, and uses their expertise to help co-create and add to our story. Together, we have the power to make meaningful change – to alter the fabric of our clients, of society and IBM itself, to create a truly positive impact and make the world work better for everyone.

It's time to define your career.

About IBM

IBM’s greatest invention is the IBMer. We believe that through the application of intelligence, reason and science, we can improve business, society and the human condition, bringing the power of an open hybrid cloud and AI strategy to life for our clients and partners around the world.Restlessly reinventing since 1911, we are not only one of the largest corporate organizations in the world, we’re also one of the biggest technology and consulting employers, with many of the Fortune 50 companies relying on the IBM Cloud to run their business. At IBM, we pride ourselves on being an early adopter of artificial intelligence, quantum computing and blockchain. Now it’s time for you to join us on our journey to being a responsible technology innovator and a force for good in the world.

Location Statement

Benefits

In addition to a competitive benefits program consisting of medical and life insurance, retirement plans, and time off, eligible employees may also have access to

IBM offers a wide range of resources for eligible IBMers to thrive both inside and outside of work.
• 12 weeks of paid parental bonding leave. Family care options are also available to support eligible employees during COVID-19.
• World-class training and educational resources on our personalized, AI-driven learning platform. IBM's learning culture supports your restless attitude to grow your skills and build the depth and scale of knowledge needed to achieve your career goals.
• Well-being programs to support mental and physical health.
• Financial programs that empower you to plan, save, and manage your money (including expert financial counseling, 401(k), IBM stock discount, etc.).
• Select educational reimbursement opportunities.
• Diverse and inclusive employee resource groups where you can network and connect with IBMers across the globe.
• Giving and volunteer programs to benefit charitable organizations and local communities.
• Discounts on retail products, services, and experiences.

The compensation range for this position is based on a full-time schedule. The salary will vary depending on your job-related skills, experience and location. Pay increment and frequency of pay will be in accordance with employment classification and applicable laws. For part time roles, your compensation will be adjusted to reflect your hours.

We consider qualified applicants with criminal histories, consistent with applicable law.

IBM will not be providing visa sponsorship for this position now or in the future. Therefore, in order to be considered for this position, you must have the ability to work without a need for current or future visa sponsorship.

Being You @ IBM

IBM is committed to creating a diverse environment and is proud to be an equal opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, gender, gender identity or expression, sexual orientation, national origin, genetics, pregnancy, disability, age, veteran status, or other characteristics. IBM is also committed to compliance with all fair employment practices regarding citizenship and immigration status.