Sr. Tax Counsel

We explore and discover the limitless possibilities of energy so we can all progress. We believe in the power of talent to shape the future. That’s why we’re looking for curious, bold individuals who are eager to grow and create new ways forward—people who want to join us in building a more sustainable, innovative, and inclusive world. We strongly believe that diversity fuels creativity and innovation. That’s why we welcome professionals who are ready to grow, learn, and bring their perspective to the energy challenges of today and tomorrow. Here, you’ll find a place to grow and unlock your full potential.

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 company’s 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 company’s tax position while maintaining compliance with applicable laws and internal governance standards.

• Monitor proposed and enacted tax legislation and assess potential impacts on the company’s 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 company’s 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 #LI-KT1