Assistant Tax Counsel

Evaluate technical merits of tax strategies, draft memoranda, and present recommendations on internal and external developments. Partner with transfer pricing, US, and international teams to drive tax planning while staying abreast of federal and foreign jurisdiction changes. Review business activities, legal structuring, and M&A transactions to advise executives on tax consequences, risks, and opportunities, including due diligence and agreement drafting. Manage financing arrangements, intercompany structures, and leverage planning. Handle federal, state, local, and foreign tax controversies, evaluate FIN 48 reserves, and ensure accurate tax accounting and reporting. Lead global M&A and business structure advice, manage outside advisor relationships, and develop continuous improvement practices using technology for compliance efficiency.