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Tax Counsel- Mergers & Acquisitions
Refer job# RSVY154426
 
Tax Counsel- Mergers & Acquisitions The candidate will advise Corporate Development and Business Development groups with respect to acquisitions, dispositions and joint venture opportunities. Will be involved throughout the deal life cycle, from opportunity identification through deal execution. Must have: Licensed in Law or Accounting (CPA). 3+ years' experience in technical tax (subchapter C, including section 367 subpart F income, the foreign tax credit system). 3+ years' experience in tax research. 3+ years' experience in tax and legal writing. Should have strong tax technical skills in areas such as: subchapter C, including section 367, subpart F income, the foreign tax credit system and should have familiarity with transfer pricing rules and the taxation of financial instruments. Should also have between 5-10 years of experience: working with senior business leaders, finance and legal teams to clearly articulate tax concepts; calculating the tax consequences of a deal for use in financial modeling; assisting the preparation of the tax section of diligence reports; reviewing financial statements and valuation reports; working with external counsel to draft 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 records; and collaborating within IBM Tax to ensure that all projects are accurately reported on IBM's tax returns and are properly documented for audit. Preferred Technical and Professional Experience: Master's Degree in Law. 5+ years' experience in technical tax (subchapter C, including section 367 subpart F income, the foreign tax credit system). 5+ years' experience in tax research. 5+ years' experience in tax and legal writing.
 
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