Expert Tax Counsel

Dow•Midland, MI

2d•$230,000 - $290,000•Hybrid

About The Position

Dow is seeking an Expert Tax Counsel to join its Tax Department and serve as a versatile, high-caliber legal and business adviser across a wide range of areas. In this role, you will support and, in many cases, take direct ownership of matters spanning tax planning and M&A, audit defense and tax controversy, tax legal research, credits & incentives, and contract review and drafting. This role offers a meaningful runway for professional growth and increasing responsibility within Dow’s tax organization. You will report to the Managing Counsel for Global Tax, who serves as Dow’s lead tax attorney and reports to the Chief Tax Officer. This position can be located in Midland, MI, Houston, TX, or virtual office in the Chicago or Detroit areas.

Requirements

Juris Doctor (J.D.) or Master of Laws.
Admission to a State Bar or eligible for admission.
A minimum of 5 years of substantive tax legal experience.
A minimum requirement for this U.S. based position is the ability to work legally in the United States. No visa sponsorship/support is available for this position, including for any type of U.S. permanent residency (green card) process.

Nice To Haves

LL.M. in Taxation.
At least 6 years of deep tax legal experience in at least one core area of tax law (e.g., Subchapter C, Subchapter K, international tax). The strongest candidates will pair that depth with the judgment, problem-solving ability, and learning agility to operate confidently across unfamiliar tax issues, and will bring the willingness to expand their expertise into new areas as the role demands.
Familiarity with IRS examination, administrative appeals, and state/local audit processes.
Familiarity with tax accounting concepts (ASC 740 / uncertain tax positions).
Prior experience at a major law firm or Big 4 accounting firm in a tax practice group; in-house tax counsel experience at a multinational also valued.
Strong legal research, analytical, and writing skills with demonstrated ability to draft technical tax memoranda and legal arguments.
Ability to review, draft, and negotiate tax provisions in commercial contracts.
Ability to manage multiple complex matters simultaneously under time pressure.
Self-starter with a collaborative mindset and comfort operating in a matrixed, global organization.

Responsibilities

Assist with the tax structuring and legal analysis of mergers, acquisitions, divestitures, joint ventures, and internal reorganizations and restructuring transactions. Support due diligence, review and draft transaction documents, and advise on post-closing integration matters.
Lead and support on audit defense and controversy matters across federal, state, local, and indirect tax areas. This includes researching and responding to Information Document Requests (IDRs) and Notices of Proposed Adjustment (NOPAs) and supporting or drafting protests, refund claims, and similar submissions. Coordinate with outside counsel on administrative appeals and litigation matters as needed.
Review and advise on tax-related provisions in a wide array of commercial agreements—including sales agreements, joint venture agreements, service contracts, licensing arrangements, and intercompany agreements—and ensure appropriate treatment of tax indemnification, cost allocation, gross-up provisions, and withholding obligations.
Conduct detailed legal research on discrete federal, state, local, and international tax questions. Draft technical memoranda documenting and supporting the company’s tax positions consistent with internal governance standards.
Assist in identifying, analyzing, and maintaining compliance with federal, state, local, and energy-related tax credits and incentives aligned with Dow’s investment strategy, including eligibility analysis and documentation support.
Partner within the Tax Department across the Tax Operations and Accounting teams and across Dow’s businesses and other functions, including Legal, M&A, Controllers, Treasury, Finance, and Government Affairs to integrate tax considerations into business planning and decision-making across the enterprise.

Benefits

Equitable and market-competitive base pay and bonus opportunity across our global markets, along with locally relevant incentives.
Benefits and programs to support your physical, mental, financial, and social well-being, to help you get the care you need...when you need it.
Competitive retirement program that may include company-provided benefits, savings opportunities, financial planning, and educational resources to help you achieve your long term financial-goals.
Employee stock purchase programs (availability varies depending on location).
Student Debt Retirement Savings Match Program (U.S. only).
Robust medical and life insurance packages that offer a variety of coverage options to meet your individual needs. Travel insurance is also available in certain countries/locations.
Opportunities to learn and grow through training and mentoring, work experiences, community involvement and team building.
Workplace culture empowering role-based flexibility to maximize personal productivity and balance personal needs.
Competitive yearly vacation allowance.
Paid time off for new parents (birthing and non-birthing, including adoptive and foster parents).
Paid time off to care for family members who are sick or injured.
Paid time off to support volunteering and Employee Resource Group’s (ERG) participation.
Wellbeing Portal for all Dow employees, our one-stop shop to promote wellbeing, empowering employees to take ownership of their entire wellbeing journey.
On-site fitness facilities to help stay healthy and active (availability varies depending on location).
Employee discounts for online shopping, cinema tickets, gym memberships and more.
Transportation allowance (availability varies depending on location)
Meal subsidiaries/vouchers (availability varies depending on location)
Carbon-neutral transportation incentives e.g. bike to work (availability varies depending on location)