M&A Tax Counsel

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

IBM is a leader in worldwide transformation and just the place to further define and develop your career in Tax. Our dedicated teams of business professionals give our clients more than solutions - we ask, "what else is possible?". As a member of our IBM Tax team, you'll have the opportunity to grow your expertise with a market leader, while exploring and connecting with virtually every part of IBM, in over 160 countries.

When you join IBM, you join a culture of openness, collaboration, and trust. Join us and experience a place where you can co-create your learning and opportunities. A place where teamwork and unique ideas are treasured. A place where you can bring innovation to life.

We are seeking an experienced Mergers & Acquisition Tax Specialist for IBM's corporate tax department. The selected candidate will advise our Corporate Development and Business Development groups with respect to acquisitions, dispositions and joint venture opportunities. The candidate will be involved throughout the deal life cycle, from opportunity identification through deal execution and integration. The ideal candidate should have strong tax technical skills in areas such as:

• Cross-border M&A
• Subchapter C, including section 367
• TCJA
• Subpart F income
• The US foreign tax credit system
• Pillar 2 rules

Required Technical and Professional Expertise

The ideal candidate should also have between 5-10 years of experience with the following:

• Working with senior business leaders, finance and legal teams to clearly articulate tax concepts
• Calculating the tax consequences of a deal for use in financial modeling
• Assisting the preparation of the tax section of diligence reports
• Working with external counsel to draft relevant contract provisions
• Developing structuring plans to guide execution in a manner that meets the business and other functional teams needs
• Working with tax accounting to ensure that transactions are properly recorded in the books and records

Preferred Technical and Professional Expertise

• Deep experience in technical tax (subchapter C, including section 367, subpart F income, the foreign tax credit system)
• Deep experience in tax research
• Deep experience in tax and legal writing
• Licensed in Law or Accounting (CPA)