Provide deep U.S. federal income tax technical guidance, with particular emphasis on Subchapter C of the Internal Revenue Code, including corporate reorganizations, distributions, liquidations, Section 355 transactions, Section 368 reorganizations, Section 351 contributions, and related consolidated return considerations. This role will serve as a senior tax technical resource for the Tax organization and cross-functional business partners, helping to design, evaluate, document, and execute tax-efficient structures that align with business objectives, manage risk, and support sustainable tax outcomes.