Director - Tax Planning​/Tax M&A

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The Director, Tax Planning /Tax M&A will provide strategic and technical leadership on U.S. federal income tax planning matters, with a primary focus on mergers, acquisitions, divestitures, restructurings, separations, and other corporate transactions. 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.

This is an onsite position with 1 day of remote work. U.S. based candidates open to relocating will be considered.

• Lead tax planning analysis and execution for significant corporate transactions, including mergers, acquisitions, divestitures, joint ventures, restructurings, separations, spin‑offs, and other strategic initiatives.
• 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.
• Partner with Legal, Treasury, Controllership, Corporate Development, FP&A, business teams, and external advisors to evaluate transaction alternatives, identify risks and opportunities, and deliver practical, business‑oriented solutions.
• Prepare, review, and manage high‑quality technical tax memoranda, transaction step plans, risk assessments, ruling requests, and other documentation supporting tax planning positions.
• Support tax due diligence, structuring, modeling, documentation, and implementation activities for domestic and cross‑border transactions.
• Collaborate with Tax Accounting & Reporting to assess the financial statement impact of tax planning positions, including ASC 740 considerations, uncertain tax positions, valuation allowance implications, and tax disclosure matters.
• Coordinate with Tax Compliance to ensure planning positions are accurately and consistently reflected in tax returns, work papers, elections, statements, and related filings.
• Monitor and analyze legislative, regulatory, IRS, Treasury, and judicial developments affecting corporate tax planning and transaction structuring; communicate impacts and recommended actions to senior Tax leadership.
• Manage external law firm and accounting firm advisors, including scoping, budgeting, work product review, and integration of advisor input into internal decision‑making.
• Build trusted relationships with Finance, Legal, Treasury, and business leadership by translating complex tax technical matters into clear, actionable guidance.
• Support audit defense by maintaining audit‑ready documentation and assisting with technical responses to tax authority inquiries related to planning transactions.
• Contribute to the development of internal tax planning processes, controls, governance standards, and knowledge‑sharing practices.

• Juris Doctor degree required; LL.M. in Taxation preferred.
• 5+ years of experience in a major law firm or comparable environment advising on complex corporate transactions, including mergers, acquisitions, divestitures, restructurings, reorganizations, and related tax planning matters.
• Strong technical foundation in U.S. federal income tax planning, mergers and acquisitions, and corporate transaction structuring.
• Deep technical knowledge of Subchapter C of the Internal Revenue Code and related Treasury Regulations, IRS guidance, and case law.
• Demonstrated ability to analyze complex tax issues, develop technically sound positions, and communicate practical recommendations to senior…