Tax-Controversy Resolution Board Adviser

The mandate

The group faces material disputes over profit allocation, permanent establishment, withholding and incentive qualification across several authorities. Local teams report technical merits and possible outcomes differently, while a settlement in one country may alter facts or negotiating positions elsewhere. The board’s standing question is which cases to defend, narrow, settle or coordinate and how those choices affect cash, precedent, disclosure posture and operating behaviour across the portfolio.

The adviser will review monthly privileged controversy packs, meet tax and legal owners before committees, attend three New York sessions and participate in one controlled evidence review. The cadence will challenge issue taxonomy, factual consistency, evidentiary strength, authority behaviour, procedural timing, settlement range, double-tax relief, collateral consequences and interdependence. Advice will frame board choices without replacing jurisdiction counsel or revealing privileged strategy unnecessarily.

The appointment runs for eight months through two major authority engagements and the annual tax-risk review. Renewal requires an explicit committee minute identifying a distinct portfolio question after management has normalised case evidence and decision ranges. The advisory seat should close when directors can compare disputes coherently; it is not continuing representation, negotiation support or external approval of every settlement.

The adviser holds no line authority and assumes no executive responsibility for tax positions, legal advice, settlement offers, authority communication, provisions, disclosure, payments or litigation. Client officers and appointed counsel retain those duties. The adviser may challenge optimism, inconsistency or weak evidence and record dissent, but cannot contact an authority or present a recommendation as a legally endorsed outcome.

Conflicts must be disclosed for tax authorities, pharmaceutical companies, advisers, law firms, audit firms, investors and counterparties implicated by shared issues. Matter-specific recusal and privilege protocols apply. The adviser accepts no success fee, settlement percentage, referral compensation or follow-on representation and will not use confidential authority intelligence for another client.

Why the board wants this voice

Local specialists know their law and relationships but naturally optimise the dispute in front of them, while group leaders must protect facts and precedent across countries. Aggregated risk summaries compress those dependencies into probability-weighted figures. Directors want a seasoned controversy strategist who can compare evidence and behaviour across matters, make cash and option value explicit and challenge settlement urgency without practising law for the company.

What you will own

• Challenge case classification by issue, jurisdiction, year, procedural stage, authority theory, factual dependency and portfolio connection.
• Compare technical advice, contemporaneous evidence, witness readiness, data reproducibility and weaknesses acknowledged by responsible counsel.
• Examine settlement ranges for cash timing, interest, penalties, relief routes, precedent and consequences in linked jurisdictions.
• Test defence and escalation choices against authority behaviour, procedural deadlines, information burden and management distraction.
• Review whether provisions and board ranges reflect consistent facts and scenario logic without making accounting determinations.
• Give directors concise defend, narrow, settle, coordinate or investigate options with uncertainty and reserved authority explicit.
• Leave a portfolio challenge map connecting each decision to evidence, cash, precedent, owner, deadline and dependent cases.

Candidate qualifications

• Has led global tax controversy portfolios involving multiple authorities, overlapping facts and material settlement choices.
• Understands transfer pricing, permanent establishment, withholding, incentives, mutual agreement and double-tax relief interactions.
• Can evaluate factual and evidentiary readiness alongside technical opinion without substituting for jurisdictional legal counsel.
• Has advised boards where settling one case changed negotiation leverage or precedent risk across other countries.
• Maintains privilege and conflict discipline while communicating ranges, uncertainty and downside in decision-ready language.
• Works independently of success fees, authority relationships and follow-on representation that could bias settlement advice.

Non-negotiables

• Can attend all New York dispute reviews and the controlled privileged evidence session within eight months.
• Will disclose authority, pharma, adviser, law-firm, audit, investment and related-counterparty relationships before matter access.
• Brings multinational controversy portfolio leadership; compliance management or single-case litigation support alone is insufficient.
• Will not contact authorities, render legal opinions or accept settlement-linked or referral compensation.

1. 49 words maximum. Describe a settlement whose portfolio precedent mattered more than its immediate cash amount.
2. 49 words maximum. How would you compare evidentiary strength across disputes governed by different legal systems?
3. 49 words maximum. Which disclosed relationship would require recusal from a controversy review?