Tax Controversy Advisory / Counsel

Introduction

At 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 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 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

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.