Nvidia Tax Counsel Controversy Planning 

United States, California 

269973498

What you'll be doing:

• Develop strategy and assist with management of US federal and state income tax audits, appeals, and other controversies from inception to resolution.

• Draft or review legal arguments, protests, and responses to Information Document Requests (IDRs) and inquiries from tax authorities.

• Partner with and manage outside counsel and external advisors on tax litigation, transfer pricing, and other complex audit matters.

• Identify, research, quantify, and document tax exposures, legal positions, and planning strategies for business initiatives, M&A transactions, investments, commercial agreements, and operational structures.

• Support the tax accounting team with the evaluation and documentation of uncertain tax positions (ASC 740).

• Collaborate with cross-functional teams to gather and prepare information as part of tax planning and controversy matters.

What we need to see:

• Juris Doctor (JD) degree from an accredited law school.

• An active license to practice law in good standing in at least one US state.

• 12+ years of relevant experience in a major law firm, Big 4 accounting firm, or an in-house tax department of a multinational corporation.

• Deep expertise in US federal income tax controversy, including IRS examinations, the administrative appeals process, and litigation.

• Proven ability to think strategically and provide practical, business-oriented legal advice on complex tax matters in a fast-paced environment.

• Excellent analytical, problem-solving, and project management skills with good judgment and strong attention to detail.

• Outstanding communication and interpersonal skills, with a demonstrated ability to collaborate effectively with internal partners and external advisors.

Ways to stand out from the crowd:

• LL.M. in Taxation.

• Significant experience with state and local tax (SALT) or non-US tax audits and controversy.

• Experience providing tax legal support for tax planning, M&A, and investments, including due diligence, structuring, and integration.

• In-depth knowledge of international tax principles, including transfer pricing.

• Experience in the technology or semiconductor industry with a strong understanding of accounting for income taxes under US GAAP (ASC 740).