Your role and responsibilities
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.
Required education
Bachelor's Degree
Preferred education
Master's Degree
Required technical and professional expertise
- Deep expertise in IRS tax controversy and audit experience, including leading complex IRS examinations, managing IDRs, negotiating issue resolution, and audit experience, including leading complex IRS examinations, managing IDRs, negotiating issue resolution, and working with IRS Appeals and litigation support.
- Deep technical expertise in U.S. and international tax matters, particularly transfer pricing, particularly transfer pricing, cross-border transactions, and other complex corporate tax issues.
- Strong leadership and stakeholder management skills, with the ability to coordinate cross-functional teams, manage external advisors, and communicate audit strategy, risk, and outcomes to senior leadership
OTHER RELEVANT JOB DETAILSIBM offers a competitive and comprehensive benefits program. Eligible employees may have access to:
- Healthcare benefits including medical & prescription drug coverage, dental, vision, and mental health & well being
- Financial programs such as 401(k), cash balance pension plan, the IBM Employee Stock Purchase Plan, financial counseling, life insurance, short & long- term disability coverage, and opportunities for performance based salary incentive programs
- Generous paid time off including 12 holidays, minimum 56 hours sick time, 120 hours vacation, 12 weeks parental bonding leave in accordance with IBM Policy, and other Paid Care Leave programs. IBM also offers paid family leave benefits to eligible employees where required by applicable law
- Training and educational resources on our personalized, AI-driven learning platform where IBMers can grow skills and obtain industry-recognized certifications to achieve their career goals
- Diverse and inclusive employee resource groups, giving & volunteer opportunities, and discounts on retail products, services & experiences
This position was posted on the date cited in the key job details section and is anticipated to remain posted for 21 days from this date or less if not needed to fill the role.
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.
The compensation range and benefits for this position are based on a full-time schedule for a full calendar year. 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 and benefits will be adjusted to reflect your hours. Benefits may be pro-rated for those who start working during the calendar year.
