Tax Counsel - Controversies & SALT

Interactive Brokers Group•Greenwich, CT

3d•Hybrid

About The Position

The Interactive Brokers Global Tax Team serves an important role in the success of our business. We mitigate risk and create value for our business and our customers. We partner with many functions across the company, including Accounting, Treasury, Technology, Customer Service and Marketing, to assist our business in achieving our commitment of delivering value through technological innovation and providing our clients with unprecedented access to global markets at the lowest cost. The Global Tax Team sets the tax policy for the company, identifies, develops, implements, and manages tax strategies to help minimize our overall tax cost. We advise on the U.S. and international tax aspects of our product offerings to customers, manage tax audits, and ensure financial reporting and tax returns are filed timely and accurately. We are looking for a Tax Counsel with deep expertise in tax controversy management and U.S. state and local taxation to join our rapidly growing Global Tax Team. The person will serve as the primary legal resource for managing federal, state, and foreign tax audits, disputes, and litigation, with a particular emphasis on state and local tax (“SALT”) controversies across multiple jurisdictions. The person will have extensive interface with key tax personnel, non-tax business executives, external counsel, and government tax authorities. A successful candidate will need to be a collaborative team player who is entrepreneurial, detail-oriented, an excellent communicator, and a skilled advocate and negotiator.

Requirements

Minimum of 7-8 years of experience in tax controversy with significant focus on U.S. state and local tax, at a nationally recognized law firm, Big 4 accounting firm, or in-house
J.D. is required; LL.M. in Taxation is plus
Admission to at least one U.S. state bar; ability to be admitted to the Connecticut or New York bar preferred
Deep expertise in U.S. state and local tax law, including corporate income and franchise tax, nexus standards, apportionment and allocation methodologies for financial services companies, and unitary business principles
Strong knowledge of tax controversy procedures at both the state and federal level, including audit management, administrative appeals, and litigation procedures
Solid foundation in U.S. federal income tax law, including Subchapter C, Subchapter K, and financial products
Working knowledge of uncertain tax positions and ASC 740-10 financial statement implications
Excellent legal research, writing, and negotiation skills
Strong business communication skills with ability to effectively relate tax issues to non-tax personnel
Advanced MS Office skills, particularly MS Excel
Strong commercial and business awareness

Nice To Haves

Prior experience with multistate tax issues specific to financial institutions, broker-dealers, or securities firms
Experience managing foreign tax controversies in coordination with international tax colleagues
Familiarity with financial products taxation at the state and federal level, including treatment of derivatives, securities lending, and investment income
Knowledge of local taxes (New York City and other municipal taxes)
Experience managing outside counsel on tax controversy matters
Familiarity with tax technology platforms and controversy management tools

Responsibilities

Serve as the primary legal advocate for managing all aspects of U.S. federal, state, and foreign tax controversies, audits, and disputes
Lead and manage state and local tax audits across multiple jurisdictions, including correspondence, negotiations, and advocacy before state and local tax authorities
Develop and execute audit defense strategies, including preparation of responses to information document requests (IDRs), notices of proposed adjustments, protests, and administrative appeals
Assess litigation risk and make recommendations to senior management on settlement versus litigation strategies
Coordinate and manage outside counsel and tax advisors engaged in tax controversy matters
Support IRS examination and appeals proceedings, including preparation of protest letters and participation in appeals conferences
Assist with managing foreign tax controversies in coordination with international tax colleagues and outside counsel
Maintain a comprehensive tracking system for all open tax audits, disputes, and litigation matters across all jurisdictions
Coordinate with the tax compliance and accounting teams to ensure audit findings and settlements are properly reflected in tax returns and financial statements, including uncertain tax positions under ASC 740-10
Develop and maintain deep expertise in state and local tax laws, regulations, rulings, and case law across jurisdictions relevant to IBKR
Advise on SALT implications of business activities and transactions, including nexus analysis, apportionment, and allocation issues specific to financial services and technology companies
Monitor legislative, regulatory, and judicial developments in SALT and assess their impact on IBKR’s tax positions and compliance obligations
Identify and evaluate SALT planning opportunities to minimize IBKR’s overall state and local tax burden
Partner with the tax compliance team to provide technical guidance on state and local tax return positions
Perform legal research on federal, state, and foreign tax controversy issues and deliver well-reasoned legal conclusions
Draft legal memoranda, technical position papers, and protest letters to document legal conclusions and tax positions
Partner with the broader Global Tax Team on tax controversy implications of business activities and transactions
Collaborate with Legal, Compliance, and Accounting teams on matters that intersect with tax controversy issues
Assist with research, development, and integration of new tax technologies, including controversy management tools and automation
Support Internal Audit/Risk Reviews and work on special projects as needed

Benefits

Competitive salary, annual performance-based bonus, and stock grant awards
401(k) retirement plan with competitive company match
Excellent health and wellness benefits, including medical, dental, and vision benefits. 100% employer-paid medical premiums, with generous employer contributions to dental & vision plans as well.
Wellness screening and assessments, health coaches, and counseling services through an Employee Assistance Program (EAP)
Generous paid parental leave (up to 16 weeks paid parental leave for eligible employees)
Company-paid basic life insurance, accidental death & dismemberment (AD&D), and short- and long-term disability coverage
Flexible Spending Accounts (Healthcare, Dependent Care, and Commuter FSAs)
Quarterly fitness stipend to offset costs associated with traditional gym and fitness memberships or fees
Education reimbursement and professional development opportunities
Legal services, telehealth access, and voluntary insurance options
Backup child and adult care support through Care.com
Daily lunch allowance and fully stocked kitchen with healthy breakfast and snack options