Counsel, Tax Controversy

This is a hybrid role and you must be located in, or wiling to relocate to, Washington, DC or San Francisco for the position.

About the Role

We are searching for a Counsel, Tax Controversy to join our Tax Team. This role will lead the management and resolution of U.S. and Canadian federal and state tax disputes, coordinate with global teams on significant non-U.S. controversies, and advise business and tax leaders on risk mitigation.

What You'll Do

• Manage, resolve, and support U.S. and Canadian federal and state income tax audits and appeals, including planning audit strategy, drafting responses and protests, and negotiating with tax authorities.
• Support and manage tax litigation matters, including coordinating with outside counsel, developing factual and legal positions, and overseeing case preparation and fact discovery through administrative and judicial stages.
• Partner with external advisors to evaluate risks, develop legal arguments, and drive favorable audit and litigation outcomes.
• Provide legal support for global tax controversy matters, including transfer pricing and complex disputes.
• Advise on legal privilege considerations and manage global implementation of privilege and document-protection policies.
• Collaborate with the Tax Planning, Tax Business Advisory, and Business Product teams to proactively identify and mitigate tax risks in emerging products and complex transactions.
• Coordinate closely with Tax Planning, Transfer Pricing, and Tax Compliance teams to ensure consistent and accurate tax positions and audit-ready documentation.
• Collaborate with Finance, Legal, and Policy to ensure consistency in litigating positions and strategic alignment and communication of tax risks and opportunities.
• Support the Tax Accounting and Provision teams by monitoring tax reserves, reviewing uncertain tax position analyses, and advising on risk associated with disclosures, amended filings, and compliance initiatives.

Basic Qualifications

• Minimum of five (5) years of legal experience in private practice, in-house, or government.
• J.D. and license to practice law in at least one U.S. state.
• Experience managing corporate tax audits, appeals, and litigations.

Preferred Qualifications

• Strong tax research and tax analytical skills working with multiple complex areas of the tax law and tax controversy administrative rules.
• Experience in broad areas of tax advisory in a large law firm and large corporate environment or federal government.
• Ability to clearly communicate recommendations based on risk analysis in a highly ambiguous environment.
• Highly organized with a strong attention to detail, ensuring clear, accurate, and well-supported submissions to tax authorities.
Familiarity with U.S. GAAP and documentation of uncertain tax positions.

For San Francisco, CA-based roles: The base salary range for this role is USD$208,000 per year - USD$231,000 per year. For Washington, DC-based roles: The base salary range for this role is USD$208,000 per year - USD$231,000 per year. For all US locations, you will be eligible to participate in Uber's bonus program, and may be offered an equity award & other types of comp. You will also be eligible for various benefits. More details can be found at the following link https://www.uber.com/careers/benefits.