IBM International Tax Counsel 

United States, New York 

200877117

information to tax operations in order to facilitate financial statement preparation and tax compliance.

The ideal candidate should also have 6-10 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 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 business needs
The ideal candidate should have strong tax technical skills in areas such as:
• US tax reform legislation and guidance (TCJA)
• U.S. tax research, writing, and analysis
• Subchapter C/cross border M&A, including section 367
• Subpart F income
• OECD Pillar 2 rules
• The U.S. foreign tax credit system, including FTC basketing and expense apportionment rules
• Familiarity with transfer pricing and partnership rules