Sr. Tax Counsel

The Sr. Tax Counsel is responsible for providing legal and strategic tax advice to support U.S. operations corporate transactions tax compliance reporting and risk management activities. Serving as a trusted advisor to U.S. business leaders and cross-functional teams including Legal Finance Accounting Treasury Corporate Tax and business development stakeholders. They will also translate complex tax matters into clear practical business-oriented guidance while maintaining strong governance and compliance standards.

Key Responsibilities

U.S. Tax Advisory and Legal Support

• Provide legal advice on U.S. federal state and local tax matters affecting the companys U.S. operations.
• Analyze tax implications of business decisions corporate initiatives restructurings financing arrangements and commercial transactions.
• Advise internal stakeholders on tax risks opportunities and compliance obligations associated with ongoing and new business activities.
• Support the interpretation and application of tax laws regulations administrative guidance and relevant case law.
• Partner with Finance Accounting Legal Treasury and business teams to ensure tax considerations are incorporated into decision-making processes.

Transactional Tax M&A and Business Development Support

• Provide tax advice and legal support for mergers acquisitions divestitures joint ventures asset transactions corporate reorganizations and strategic transactions.
• Support tax due diligence processes including identification of tax exposures tax attributes historical compliance and potential transaction risks.
• Review draft and negotiate tax-related provisions in transaction documents including tax indemnities representations warranties covenants and closing deliverables.
• Coordinate with Legal Finance Corporate Development and business teams to evaluate transaction structures and after-tax economics.
• Work with external counsel and tax advisors to obtain specialized advice opinions and technical support when required.

Corporate Structuring and Tax Planning

• Advise on tax-efficient corporate legal entity and financing structures for U.S. operations and investments.
• Support development and implementation of U.S. tax planning strategies aligned with business objectives and global tax policies.
• Analyze tax impact of internal debt equity funding repatriation cash movements and intercompany arrangements.
• Identify opportunities to optimize the companys tax position while maintaining compliance with applicable laws and internal governance standards.
• Monitor proposed and enacted tax legislation and assess potential impacts on the companys business operations and tax profile.

International Tax and Cross-Border Matters

• Provide advice on U.S. international tax matters including inbound and outbound structures withholding tax foreign tax credits Subpart F GILTI BEAT FDII treaty analysis and cross-border financing.
• Support legal and tax analysis related to intercompany transactions foreign operations and international investments.
• Collaborate with global tax teams to align U.S. tax advice with broader corporate tax strategy.
• Advise on tax implications of cross-border employee service royalty financing and asset arrangements.
• Support international tax reporting and documentation requirements as needed.

Transfer Pricing

• Provide legal support for transfer pricing policies intercompany agreements and documentation requirements.
• Work with Corporate Tax Finance and external advisors to assess transfer pricing risks and support compliance with U.S. and international requirements.
• Review and advise on intercompany service arrangements cost-sharing management fees intellectual property arrangements financing transactions and other related-party dealings.
• Support transfer pricing audits information requests and controversy matters.

Tax Compliance Reporting and Provision Support

• Support internal teams and external advisors in connection with federal state local and withholding tax filings.
• Provide legal review and technical support for uncertain tax positions tax reserves and income tax accounting matters.
• Assist with tax provision processes including quarterly and annual tax reporting tax disclosures and related documentation.
• Support development and maintenance of documentation for tax positions including technical memoranda and legal analyses.
• Partner with Accounting and Finance to ensure tax positions are properly analyzed documented and reflected in financial reporting.

Tax Controversy Audits and Risk Management

• Manage and support federal state and local tax audits inquiries notices and disputes.
• Develop audit defense strategies and coordinate responses to tax authority information requests.
• Work with external counsel advisors and internal stakeholders to resolve tax controversies efficiently and appropriately.
• Assess tax risks and recommend mitigation strategies.
• Maintain strong documentation and governance practices to support the companys tax positions.

Indirect Tax Property Tax and Other U.S. Tax Matters

• Provide legal and technical support on sales and use tax property tax excise tax gross receipts tax and other indirect tax matters as needed.
• Advise stakeholders on tax clauses in commercial contracts procurement agreements service agreements and business arrangements.
• Coordinate with external advisors and internal teams to address state and local tax matters.
• Support special projects involving incentives exemptions credits abatements or other tax-related opportunities.

Contract Review and Commercial Support

• Review tax-related provisions in customer vendor supplier EPC service procurement financing and commercial agreements.
• Advise business and legal teams on withholding tax gross-up clauses tax indemnities invoicing requirements permanent establishment risks and indirect tax considerations.
• Provide practical recommendations to reduce tax risk while supporting business objectives.
• Collaborate with Legal and Procurement teams to standardize tax language and improve contract governance.

External Advisor Management and Internal Collaboration

• Manage and coordinate external tax counsel accounting firms and other advisors to ensure high-quality cost-effective support.
• Serve as a trusted tax legal advisor to business leaders corporate functions and project teams.
• Prepare and present tax analysis recommendations and updates to senior stakeholders.
• Translate complex tax concepts into clear business terms for non-tax audiences.
• Promote collaboration across Legal Tax Finance Accounting Treasury HR and business teams.

Required Qualifications

• Juris Doctor degree from an accredited U.S. law school.
• Active membership in good standing with at least one U.S. State Bar.
• At least 5 years of relevant tax experience preferably with a combination of law firm Big Four and in-house corporate tax experience.
• Strong knowledge of U.S. federal corporate income tax law.
• Experience with U.S. state and local tax matters.
• Experience advising on M&A joint ventures corporate reorganizations financing structures and commercial transactions.
• Strong understanding of international tax principles and cross-border tax planning.
• Experience with tax controversy audits and tax authority interactions.
• Ability to review draft and negotiate tax provisions in legal agreements.
• Strong analytical legal research and technical writing skills.
• Excellent verbal and written communication skills.
• Ability to manage multiple priorities work independently and provide timely advice in a fast-paced business environment.
• Must be authorized to work in the United States.

Preferred Qualifications

• LL.M. in Taxation strongly preferred.
• CPA license or prior accounting background is a plus but not required if the candidate has strong legal tax experience.
• Experience in the energy oil and gas renewables infrastructure industrial or capital-intensive sectors.
• Experience with tax credits incentives cost segregation property tax and energy-related tax matters.
• Familiarity with ASC 740 FIN 48 and tax provision processes.
• Experience with SAP OneSource Checkpoint Bloomberg Tax BNA or similar tax research and compliance tools.
• Experience managing outside counsel and external tax advisors.
• Prior experience working with global or multinational corporate structures.
• Spanish language skills are a plus particularly for coordination with corporate teams and cross-border stakeholders.

Repsol is an Equal Opportunity Employer M/F/Disability/Veteran

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