Senior Tax Counsel - US Tax Planning, Controversy & Transactions

About the role

We are seeking a Senior Tax Counsel to join our global tax organization and provide expert legal support on U.S. domestic tax matters. The role focuses on tax planning, controversy management, and strategic transaction work, including mergers, acquisitions, and financing initiatives.

Key responsibilities

• Advise business and tax leaders on U.S. tax implications of operations, investments, and strategic projects.
• Design and implement tax‑efficient structures for complex transactions while ensuring compliance.
• Lead responses to IRS examinations, develop audit strategies, and prepare technical memoranda, protest letters, and rulings.
• Coordinate with outside counsel on significant tax controversies and support appeals or litigation as needed.
• Conduct tax due diligence for acquisitions, divestitures, joint ventures, and restructurings; draft and negotiate tax provisions in transaction documents.
• Provide guidance on federal energy tax credits, government incentives, and advanced manufacturing programs.

Required profile

• Juris Doctor (JD) degree.
• 7+ years of experience in a top law firm, accounting firm, or corporate tax department.
• Strong technical expertise in U.S. federal tax law, tax controversy, and transaction tax.
• Demonstrated business judgment and ability to collaborate across finance, treasury, accounting, and legal teams.
• Experience with energy tax credits or government incentive programs is a plus.

Required skills

• U.S. federal tax law
• Tax controversy and audit handling
• M&A tax due diligence
• Energy tax credit analysis
• Government incentive expertise