Expert Tax Counsel

About you and this the role 

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. 

Responsibilities 

• M&A and Tax Planning Advisory: 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.
• Tax Controversy and Audit Defense: 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. 
• Contract Review & Commercial Advisory: 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. 
• Tax Legal Research & Memoranda: 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. 
• Credits & Incentives: 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. 
• Cross-Functional Collaboration: 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. 

Required Qualifications 

• 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. 

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Preferred Qualifications 

• 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. 

Skills 

• 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. 

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Additional Notes 

• Relocation assistance is not available for this position. 
• For positions based in Illinois, Dow is required by law to include the pay scale that is reasonably expected to represent the pay range for the position. This pay range relates specifically to this role opening in Illinois and accounts for both new and experienced employees with consideration to factors including but not limited to skillset, experience, and sustained job performance (or similar jobs). A reasonable pay range for this position is: $230,000 - $290,000.