Sr. Tax Counsel

Sr. Tax Counsel

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The Sr. Tax Counsel is responsible for providing legal and strategic tax advice to support U.S. operations, corporate transactions, tax compliance, reporting, and risk management activities. Serving as a trusted advisor to U.S. business leaders and cross-functional teams including Legal, Finance, Accounting, Treasury, Corporate Tax, and business development stakeholders. They will also translate complex tax matters into clear, practical, business-oriented guidance while maintaining strong governance and compliance standards.

Key Responsibilities

U.S. Tax Advisory and Legal Support

• Provide legal advice on U.S. federal, state, and local tax matters affecting the company's U.S. operations.
• Analyze tax implications of business decisions, corporate initiatives, restructurings, financing arrangements, and commercial transactions.
• Advise internal stakeholders on tax risks, opportunities, and compliance obligations associated with ongoing and new business activities.
• Support the interpretation and application of tax laws, regulations, administrative guidance, and relevant case law.
• Partner with Finance, Accounting, Legal, Treasury, and business teams to ensure tax considerations are incorporated into decision-making processes.

Transactional Tax, M&A, and Business Development Support

• Provide tax advice and legal support for mergers, acquisitions, divestitures, joint ventures, asset transactions, corporate reorganizations, and strategic transactions.
• Support tax due diligence processes, including identification of tax exposures, tax attributes, historical compliance, and potential transaction risks.
• Review, draft, and negotiate tax-related provisions in transaction documents, including tax indemnities, representations, warranties, covenants, and closing deliverables.
• Coordinate with Legal, Finance, Corporate Development, and business teams to evaluate transaction structures and after-tax economics.
• Work with external counsel and tax advisors to obtain specialized advice, opinions, and technical support when required.

Corporate Structuring and Tax Planning

• Advise on tax-efficient corporate, legal entity, and financing structures for U.S. operations and investments.
• Support development and implementation of U.S. tax planning strategies aligned with business objectives and global tax policies.
• Analyze tax impact of internal debt, equity funding, repatriation, cash movements, and intercompany arrangements.
• Identify opportunities to optimize the company's tax position while maintaining compliance with applicable laws and internal governance standards.
• Monitor proposed and enacted tax legislation and assess potential impacts on the company's business, operations, and tax profile.

International Tax and Cross-Border Matters

• Provide advice on U.S. international tax matters, including inbound and outbound structures, withholding tax, foreign tax credits, Subpart F, GILTI, BEAT, FDII, treaty analysis, and cross-border financing.
• Support legal and tax analysis related to intercompany transactions, foreign operations, and international investments.
• Collaborate with global tax teams to align U.S. tax advice with broader corporate tax strategy.
• Advise on tax implications of cross-border employee, service, royalty, financing, and asset arrangements.
• Support international tax reporting and documentation requirements as needed.

Transfer Pricing

• Provide legal support for transfer pricing policies, intercompany agreements, and documentation requirements.
• Work with Corporate Tax, Finance, and external advisors to assess transfer pricing risks and support compliance with U.S. and international requirements.
• Review and advise on intercompany service arrangements, cost-sharing, management fees, intellectual property arrangements, financing…