Counsel, Global Tax Controversy

Keysight is at the forefront of technology innovation, delivering breakthroughs and trusted insights in electronic design, simulation, prototyping, test, manufacturing, and optimization. Our ~15,000 employees create world-class solutions in communications, 5G, automotive, energy, quantum, aerospace, defense, and semiconductor markets for customers in over 100 countries. Learn more about what we do.

Our award-winning culture embraces a bold vision of where technology can take us and a passion for tackling challenging problems with industry-first solutions. We believe that when people feel a sense of belonging, they can be more creative, innovative, and thrive at all points in their careers.

Keysight is seeking a Counsel, Global Tax Controversy to join our global Tax team and provide strategic leadership across a diverse portfolio of complex U.S. and international tax audits, disputes, and related matters. This highly collaborative, hands-on role is ideal for an experienced tax controversy professional who can independently lead complex matters, exercise sound judgment, bring together the right subject-matter experts, and drive issues from strategy through resolution.

Working closely with Tax colleagues, cross-functional business partners, outside advisors, and tax authorities around the world, this individual will develop and execute strategies for significant tax controversy matters across multiple jurisdictions, including U.S. federal, state and local, and non-U.S. audits. The role will also partner with Keysight's tax planning, international tax, and transfer pricing teams to assess potential controversy risks and provide strategic guidance on mitigating those risks.

This is an opportunity to serve as a trusted advisor within a small, experienced global Tax team, with significant ownership of complex matters, broad exposure across Keysight's global organization, and the ability to influence strategies and decisions with meaningful business impact.

The Counsel, Global Tax Controversy will play a critical role within Keysight's Tax Department, managing complex U.S. and non-U.S. tax controversy matters and developing and executing strategies for audits, disputes, and related proceedings. This individual will advise on tax controversy risks and opportunities arising from Keysight's global business operations, transfer pricing policies, global trade activities, and material transactions.

Reporting to the Director, Tax Controversy & Risk Management, this role will work closely with colleagues across the Tax Department and partner with functions including Controllership, Corporate Development, Legal, Logistics, and Treasury. The Counsel will independently manage complex matters, coordinate internal and external subject-matter experts, and drive tax controversies from initial audit through resolution in alignment with broader global tax controversy strategies.

Primary responsibilities include:

• Develop and execute strategies for U.S. and non-U.S. tax audits, disputes, and related proceedings, including advance pricing agreements.
• Independently manage U.S. federal income tax audits, including coordinating the review and response to IRS Information Document Requests.
• Manage state and local tax audits and oversee material non-U.S. income tax audits.
• Partner with International Tax and Transfer Pricing leadership to manage global transfer pricing audits and coordinate trade and customs audit matters.
• Assess complex tax controversy issues, identify risks and potential outcomes, and provide recommendations to Tax leadership and cross-functional stakeholders.
• Research and draft memoranda documenting tax positions, prepare FIN 48 analyses, and develop materials supporting negotiations with government authorities.
• Coordinate cross-functional teams and subject-matter experts across jurisdictions to effectively manage complex controversy matters and drive them toward resolution.
• Manage outside tax advisors and counsel, bringing in external expertise as appropriate to support effective strategies and outcomes.
• Partner with tax planning, international tax, and transfer pricing teams to identify potential controversy risks and advise on opportunities to mitigate those risks as significant business decisions and transactions are considered.

• JD degree required. Typically 10+ years of relevant experience, including experience in tax controversy at a law firm, Big 4 accounting firm, and/or multinational corporation.
• Demonstrated experience managing complex tax audits, disputes, or other controversy matters, including U.S. federal, state and local, and/or non-U.S. tax matters.
• Experience working with tax authorities and managing audit processes, including coordinating responses, developing positions, and working with internal and external subject-matter experts.
• Experience with international tax and transfer pricing matters.
• Working knowledge of M&A transactions and related tax considerations and potential controversy risks.
• Strong project management and organizational skills, with the ability to independently manage multiple complex matters, stakeholders, and priorities.
• Strong analytical and problem-solving skills, with demonstrated ability to assess multidimensional issues, exercise sound judgment, and develop practical solutions.
• Excellent written, verbal, and interpersonal communication skills, with the ability to collaborate effectively with business and functional leaders, subject-matter experts, outside advisors, and colleagues across geographies.
• Demonstrated ability to work independently, take ownership of complex matters, and operate as a strategic thought partner while maintaining alignment with broader tax strategies and objectives.
• Highest standards of integrity, business controls, and business practices.

Preferred Qualifications:

• Experience with IRS audits and appeals and/or state and local tax audits.
• Experience managing tax controversy matters within a multinational corporation.
• Experience with global or multi-jurisdictional tax audits and disputes.
• Experience with cost sharing and intellectual property valuation matters.
• Experience with advance pricing agreements and transfer pricing controversies.
• Experience with trade compliance, customs, supply chain management, or trade law.
• Experience managing outside tax advisors and counsel.

Careers Privacy Statement

Keysight is an Equal Opportunity Employer

Keysight Technologies Inc. is an equal opportunity employer. Qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, protected veteran status, disability or any other protected categories under all applicable laws.

Pay Transparency

The level of role will be based on applicable experience, education, and skills. Most offers will be between the minimum and the midpoint of the Salary Range listed below.

San Francisco, Bay Area Pay Range: Minimum $215,260 - Maximum $404,550

Note: For other locations, pay ranges will vary by region

US Employees may be eligible for the following benefits:

• Medical, dental and vision
• Health Savings Account
• Health Care and Dependent Care Flexible Spending Accounts
• Life, Accident, Disability insurance
• Business Travel Accident and Business Travel Health
• 401(k) Plan
• Flexible Time Off, Paid Holidays
• Paid Family Leave
• Discounts, Perks
• Tuition Reimbursement
• Adoption Assistance
• ESPP (Employee Stock Purchase Plan)
• Restricted Stock Units
• Bonus Program