Tax Controversy Attorney – IRS Audits & Dispute Management

About the role

IBM Finance & Operations is seeking an experienced Tax Controversy Attorney/Analyst to join its Global Tax Controversy team in Armonk, New York. You will lead IRS examinations, manage complex tax disputes, and serve as the primary liaison between IBM and the IRS.

Key responsibilities

• Lead all aspects of IRS audits, including strategy development, IDR management, and issue resolution.
• Act as the main point of contact with IRS examination teams, ensuring consistent engagement across audit workstreams.
• Defend IBM’s tax positions on transfer pricing, cross‑border transactions, and other international tax matters.
• Draft protests, engage with IRS Appeals, and support litigation when required.
• Coordinate with finance, accounting, business units, and external advisors.
• Advise senior leadership on audit developments, risk assessments, and strategic outcomes.

Required profile

• Deep expertise in IRS tax controversy and audit experience, including leading complex examinations and managing IDRs.
• Strong technical knowledge of U.S. and international tax issues, especially transfer pricing and cross‑border transactions.
• Proven ability to manage stakeholder relationships and communicate audit strategy to senior leaders.

Required skills

• IRS audit procedures
• Transfer pricing analysis
• International tax compliance
• Tax controversy management
• Tax litigation support

What we offer

• Continuous learning and career development opportunities.
• A culture that values diverse perspectives.
• Access to IBM’s global resources and innovative environment.