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

　　We are seeking an experienced candidate with very strong U.S. international tax technical and project management skills to join IBM's corporate tax department as International Tax Counsel. The selected candidate will perform significant U.S. tax technical research, writing, and analysis, and will work closely with various business units, country management and advisors to create and implement strategies to address business issues. In addition, the candidate will provide on-going monitoring of, and commentary on, applicable tax legislation and regulations; and provide timely

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

　　Required Technical and Professional Expertise

　　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

　　Preferred Technical and Professional Expertise

　　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

　　About Business UnitThe IBM Finance organization is responsible for driving enterprise performance and transformation. We are the financial stewards of IBM, delivering IBM's financial strategy, developing new business models, and mitigating enterprise risk. Do you have a passion for creating business value? Join our team in accounting, financial planning, pricing, business controls, tax, treasury, business development (acquisitions & divestitures), and global financing.

　　Your Life @ IBMIn a world where technology never stands still, we understand that, dedication to our clients success, innovation that matters, and trust and personal responsibility in all our relationships, lives in what we do as IBMers as we strive to be the catalyst that makes the world work better.

　　Being an IBMer means you'll be able to learn and develop yourself and your career, you'll be encouraged to be courageous and experiment everyday, all whilst having continuous trust and support in an environment where everyone can thrive whatever their personal or professional background.

　　Our IBMers are growth minded, always staying curious, open to feedback and learning new information and skills to constantly transform themselves and our company. They are trusted to provide on-going feedback to help other IBMers grow, as well as collaborate with colleagues keeping in mind a team focused approach to include different perspectives to drive exceptional outcomes for our customers. The courage our IBMers have to make critical decisions everyday is essential to IBM becoming the catalyst for progress, always embracing challenges with resources they have to hand, a can-do attitude and always striving for an outcome focused approach within everything that they do.

　　Are you ready to be an IBMer?

　　About IBMIBM's greatest invention is the IBMer. We believe that through the application of intelligence, reason and science, we can improve business, society and the human condition, bringing the power of an open hybrid cloud and AI strategy to life for our clients and partners around the world.Restlessly reinventing since 1911, we are not only one of the largest corporate organizations in the world, we're also one of the biggest technology and consulting employers, with many of the Fortune 50 companies relying on the IBM Cloud to run their business. At IBM, we pride ourselves on being an early adopter of artificial intelligence, quantum computing and blockchain. Now it's time for you to join us on our journey to being a responsible technology innovator and a force for good in the world.

　　Location StatementIBM 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), 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 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. 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. We consider qualified applicants with criminal histories, consistent with applicable law.

　　Being You @ IBMIBM 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.