Senior Tax Counsel - US Tax Planning, Controversy & Transactions

The Senior Tax Counsel will serve as a key member of the Company's global tax organization and provide legal support across a broad range of U.S. domestic tax matters. This role will focus on domestic tax planning, tax controversy (audit and appeals), and strategic transaction support, including mergers, acquisitions, restructurings, joint ventures, and financing transactions.

The ideal candidate will have 7+ years of experience in a leading law firm, accounting firm, or corporate tax department and possess strong technical tax expertise, sound business judgment, and the ability to collaborate effectively with other members of the Tax function and across legal, finance, treasury, accounting, and business teams. Experience with federal energy tax credits, government incentives, and advanced manufacturing incentives is a plus.

The Senior Tax Counsel will serve as a key member of the Company's global tax organization and provide legal support across a broad range of U.S. domestic tax matters. This role will focus on domestic tax planning, tax controversy (audit and appeals), and strategic transaction support, including mergers, acquisitions, restructurings, joint ventures, and financing transactions. The ideal candidate will have 7+ years of experience in a leading law firm, accounting firm, or corporate tax department and possess strong technical tax expertise, sound business judgment, and the ability to collaborate effectively with other members of the Tax function and across legal, finance, treasury, accounting, and business teams. Experience with federal energy tax credits, government incentives, and advanced manufacturing incentives is a plus.

You Will...

U.S. Tax Planning

• Advise business leaders and tax leadership on U.S. domestic tax matters affecting the Company's operations, investments, and strategic initiatives.

• Analyze and structure complex transactions to achieve tax-efficient outcomes while managing risk and ensuring compliance.

• Provide legal support for financing transactions, supply chain initiatives, manufacturing investments, intellectual property arrangements, and other business initiatives.

• Monitor legislative, regulatory, and administrative developments and assess their impact on the Company.

• Collaborate with accounting, treasury, legal, and business teams on tax implications of operational decisions, and the development and implementation of tax strategies.

Tax Controversy, Audit & Appeals

• Support responses to IRS tax examinations.

• Assist in the development of audit strategies and defend complex tax issues.

• Prepare technical memoranda, protest letters, ruling requests, and other submissions to taxing authorities.

• Coordinate with outside counsel and advisors on significant tax controversies.

• Support administrative appeals, alternative dispute resolution efforts, and litigation matters as needed.

Mergers, Acquisitions & Strategic Transactions

• Provide tax support for acquisitions, divestitures, joint ventures, restructurings, and other strategic transactions.

• Conduct tax due diligence and evaluate transaction risks and opportunities.

• Assist in drafting and negotiating tax provisions in purchase agreements, joint venture agreements, financing documents, and other transaction-related contracts.

• Partner with corporate strategyt, finance, and legal teams throughout the transaction lifecycle.

Energy Credits & Government Incentives (Preferred)

• Advise on the federal tax treatment and monetization of energy-related tax credits and incentives, including advanced manufacturing and clean energy programs.

• Support tax analysis related to domestic incentive packages associated with manufacturing and capital investment projects.

• Monitor developments involving energy tax credits, transferable credits, direct pay mechanisms, and related regulatory guidance.

You Will...

U.S. Tax Planning

• Advise business leaders and tax leadership on U.S. domestic tax matters affecting the Company's operations, investments, and strategic initiatives.

• Analyze and structure complex transactions to achieve tax-efficient outcomes while managing risk and ensuring compliance.

• Provide legal support for financing transactions, supply chain initiatives, manufacturing investments, intellectual property arrangements, and other business initiatives.

• Monitor legislative, regulatory, and administrative developments and assess their impact on the Company.

• Collaborate with accounting, treasury, legal, and business teams on tax implications of operational decisions, and the development and implementation of tax strategies.

Tax Controversy, Audit & Appeals

• Support responses to IRS tax examinations.

• Assist in the development of audit strategies and defend complex tax issues.

• Prepare technical memoranda, protest letters, ruling requests, and other submissions to taxing authorities.

• Coordinate with outside counsel and advisors on significant tax controversies.

• Support administrative appeals, alternative dispute resolution efforts, and litigation matters as needed.

Mergers, Acquisitions & Strategic Transactions

• Provide tax support for acquisitions, divestitures, joint ventures, restructurings, and other strategic transactions.

• Conduct tax due diligence and evaluate transaction risks and opportunities.

• Assist in drafting and negotiating tax provisions in purchase agreements, joint venture agreements, financing documents, and other transaction-related contracts.

• Partner with corporate strategyt, finance, and legal teams throughout the transaction lifecycle.

Energy Credits & Government Incentives (Preferred)

• Advise on the federal tax treatment and monetization of energy-related tax credits and incentives, including advanced manufacturing and clean energy programs.

• Support tax analysis related to domestic incentive packages associated with manufacturing and capital investment projects.

• Monitor developments involving energy tax credits, transferable credits, direct pay mechanisms, and related regulatory guidance.