International Tax Counsel

IntroductionAt IBM Finance & Operations, we are the backbone of IBM’s transformation driving efficiency, transparency, and smart decision-making across the business. Our teams provide the insight and discipline that guide strategy, ensure financial strength, and enable IBM to invest in innovation and growth. Working in Finance & Operations means combining analytical skills with collaboration and curiosity. You’ll partner with colleagues across functions and geographies, using data, technology, and process excellence to create solutions that improve performance and deliver measurable impact. IBM offers continuous learning, career development, and a culture that values diverse perspectives. Join us and be part of a global team that keeps IBM moving forward, while building your own future in a dynamic and evolving environment.Your role and responsibilitiesIBM 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 International Tax Specialist for IBM’s corporate tax department. The selected candidate will advise our Corporate Tax, Treasury, and Legal Departments with respect to capital structuring, financial operations, and corporate restructurings. The candidate will play a critical role in identifying and implementing opportunities that drive IBM’s tax policies and strategies. The ideal candidate should have strong tax technical skills in areas such as:

• Subchapter C, including section 367
• NCTI, Subpart F, and other international rules
• Dividends and E&P mechanics, included related foreign exchange rules
• The US foreign tax credit system
• Taxation of financial transactions
• Pillar 2 rulesRequired technical and professional expertiseThe ideal candidate should also have between 5-10 years of experience with the following:
• Working with clients or senior business leaders, finance and legal teams to clearly articulate tax concepts
• Characterizing, analyzing, and computing tax consequences of corporate structuring transactions
• Modeling the financial impact of proposed financial transactions
• Working with external counsel to draft and review 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 recordsPreferred technical and professional experience
• At least 8 years’ experience in technical tax (subchapter C, including section 367, subpart F income, the foreign tax credit system)
• At least 8 years’ experience in tax research
• At least 8 years’ experience in tax and legal writing
• JD or CPA IBM is committed to creating a diverse environment and is proud to be an equal-opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, gender, gender identity or expression, sexual orientation, national origin, caste, genetics, pregnancy, disability, neurodivergence, age, veteran status, or other characteristics. IBM is also committed to compliance with all fair employment practices regarding citizenship and immigration status.