layiq

/la·yiq/adjective

worthy; deserving; fitting; suitable.

A role, opportunity, or path that merits attention, time, and pursuit.

Counsel, Global Tax Controversy at Keysight Technologies | LAYIQ

The Counsel, Global Tax Controversy will play a critical role within Keysight's Tax Department, managing complex U.S. and non-U.S. tax controversy matters and developing and executing strategies for audits, disputes, and related proceedings. This individual will advise on tax controversy risks and opportunities arising from Keysight's global business operations, transfer pricing policies, global trade activities, and material transactions.
Reporting to the Director, Tax Controversy & Risk Management, this role will work closely with colleagues across the Tax Department and partner with functions including Controllership, Corporate Development, Legal, Logistics, and Treasury. The Counsel will independently manage complex matters, coordinate internal and external subject-matter experts, and drive tax controversies from initial audit through resolution in alignment with broader global tax controversy strategies.
Primary responsibilities include: Develop and execute strategies for U.S. and non-U.S. tax audits, disputes, and related proceedings, including advance pricing agreements.
Independently manage U.S. federal income tax audits, including coordinating the review and response to IRS Information Document Requests.
Manage state and local tax audits and oversee material non-U.S. income tax audits.
Partner with International Tax and Transfer Pricing leadership to manage global transfer pricing audits and coordinate trade and customs audit matters.
Assess complex tax controversy issues, identify risks and potential outcomes, and provide recommendations to Tax leadership and cross-functional stakeholders.
Research and draft memoranda documenting tax positions, prepare FIN 48 analyses, and develop materials supporting negotiations with government authorities.
Coordinate cross-functional teams and subject-matter experts across jurisdictions to effectively manage complex controversy matters and drive them toward resolution.
Manage outside tax advisors and counsel, bringing in external expertise as appropriate to support effective strategies and outcomes.
Partner with tax planning, international tax, and transfer pricing teams to identify potential controversy risks and advise on opportunities to mitigate those risks as significant business decisions and transactions are considered.

Responsibilities

The Counsel, Global Tax Controversy will play a critical role within Keysight's Tax Department, managing complex U.S. and non-U.S. tax controversy matters and developing and executing strategies for audits, disputes, and related proceedings. This individual will advise on tax controversy risks and opportunities arising from Keysight's global business operations, transfer pricing policies, global trade activities, and material transactions.
Reporting to the Director, Tax Controversy & Risk Management, this role will work closely with colleagues across the Tax Department and partner with functions including Controllership, Corporate Development, Legal, Logistics, and Treasury. The Counsel will independently manage complex matters, coordinate internal and external subject-matter experts, and drive tax controversies from initial audit through resolution in alignment with broader global tax controversy strategies.
Primary responsibilities include: Develop and execute strategies for U.S. and non-U.S. tax audits, disputes, and related proceedings, including advance pricing agreements.
Independently manage U.S. federal income tax audits, including coordinating the review and response to IRS Information Document Requests.
Manage state and local tax audits and oversee material non-U.S. income tax audits.
Partner with International Tax and Transfer Pricing leadership to manage global transfer pricing audits and coordinate trade and customs audit matters.
Assess complex tax controversy issues, identify risks and potential outcomes, and provide recommendations to Tax leadership and cross-functional stakeholders.
Research and draft memoranda documenting tax positions, prepare FIN 48 analyses, and develop materials supporting negotiations with government authorities.
Coordinate cross-functional teams and subject-matter experts across jurisdictions to effectively manage complex controversy matters and drive them toward resolution.
Manage outside tax advisors and counsel, bringing in external expertise as appropriate to support effective strategies and outcomes.
Partner with tax planning, international tax, and transfer pricing teams to identify potential controversy risks and advise on opportunities to mitigate those risks as significant business decisions and transactions are considered.

Qualifications

JD degree required. Typically 10+ years of relevant experience, including experience in tax controversy at a law firm, Big 4 accounting firm, and/or multinational corporation.
Demonstrated experience managing complex tax audits, disputes, or other controversy matters, including U.S. federal, state and local, and/or non-U.S. tax matters.
Experience working with tax authorities and managing audit processes, including coordinating responses, developing positions, and working with internal and external subject-matter experts.
Experience with international tax and transfer pricing matters.
Working knowledge of M&A transactions and related tax considerations and potential controversy risks.
Strong project management and organizational skills, with the ability to independently manage multiple complex matters, stakeholders, and priorities.
Strong analytical and problem-solving skills, with demonstrated ability to assess multidimensional issues, exercise sound judgment, and develop practical solutions.
Excellent written, verbal, and interpersonal communication skills, with the ability to collaborate effectively with business and functional leaders, subject-matter experts, outside advisors, and colleagues across geographies.
Demonstrated ability to work independently, take ownership of complex matters, and operate as a strategic thought partner while maintaining alignment with broader tax strategies and objectives.
Highest standards of integrity, business controls, and business practices.

Preferred Qualifications:

Experience with IRS audits and appeals and/or state and local tax audits.
Experience managing tax controversy matters within a multinational corporation.
Experience with global or multi-jurisdictional tax audits and disputes.
Experience with cost sharing and intellectual property valuation matters.
Experience with advance pricing agreements and transfer pricing controversies.
Experience with trade compliance, customs, supply chain management, or trade law.
Experience managing outside tax advisors and counsel.
Careers Privacy Statement
Keysight is an Equal Opportunity Employer
Keysight Technologies Inc. is an equal opportunity employer. Qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, protected veteran status, disability or any other protected categories under all applicable laws.

Counsel, Global Tax Controversy

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Responsibilities

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Preferred Qualifications:

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