Tax Controversy Advisory Counsel

IBM is seeking an experienced Tax Controversy Attorney/Analyst to join its Global Tax Controversy team in Armonk, New York.

This role will lead and manage IRS examinations and disputes involving complex U.S. tax matters. The successful candidate will serve as IBM's primary liaison with IRS examination teams and will coordinate the company's overall audit strategy.

Key responsibilities include:

• Leading all aspects of IRS audits, including developing audit strategies, managing Information Document Requests (IDRs), and driving issue resolution in collaboration with IRS teams.
• Serving as the primary point of contact with the IRS to ensure consistent, disciplined engagement and alignment across multiple audit workstreams.
• Defending the company's tax positions on matters involving transfer pricing, cross-border transactions, and other international tax issues.
• Managing dispute resolution and escalations, including drafting protests, engaging with IRS Appeals, and supporting litigation as needed.
• Coordinating with cross-functional stakeholders, including finance, accounting, business teams, and external advisors.
• Advising senior leadership on audit developments, risk assessments, potential outcomes, and strategic considerations.