Sr. Tax Counsel

Description

POSITION DESCRIPTION:

Qcells is seeking a Senior Tax Counsel to support the company’s U.S. tax-credit strategy and legal compliance, with a primary focus on federal clean energy tax credits under Sections 45X and 48E of the Internal Revenue Code, as enacted and amended under the Inflation Reduction Act (IRA) and subsequent legislation.

This role will advise on tax-credit eligibility, qualification, structuring, monetization, and compliance across Qcells’ U.S. solar manufacturing, supply chain, and clean energy investment activities. The position will work closely with legal, tax, finance, accounting, operations, and commercial teams, as well as outside tax counsel and other advisors, to support the company’s strategic objectives in a changing tax and energy policy environment.

This position is based in Washington D.C and requires working on-site five days a week. Some travel required approx. 10-15%

Responsibilities

• Advise on the eligibility, availability, and application of Section 45X advanced manufacturing production credits and Section 48E clean electricity investment credits, including relevant statutory, regulatory, and IRS guidance.
• Evaluate tax-credit opportunities and risks associated with Qcells’ U.S. solar manufacturing, eligible components, clean energy projects, investments, and related commercial arrangements.
• Partner with tax, finance, accounting, operations, engineering, procurement, and business teams to assess qualification requirements, supporting documentation, reporting obligations, and internal controls.
• Monitor and assess developments in federal tax legislation, Treasury regulations, IRS guidance, and related energy and manufacturing policies that may affect Sections 45X and 48E.
• Advise on applicable domestic content or other bonus-credit considerations, and other qualification conditions where relevant to the company’s activities.
• Develop practical guidance, processes, and training to support tax-credit compliance, substantiation, recordkeeping, registration, reporting, and audit readiness.
• Coordinate with outside tax counsel, accounting firms, transaction counterparties, lenders, investors, and other stakeholders on tax-credit matters, as appropri
  
  

Required Qualifications

• J.D. from an accredited law school and active membership in at least one U.S. state bar.
• 5 years of relevant legal or tax experience in federal tax, energy, manufacturing, project finance, corporate transactions, or a related area.
• Working knowledge of the Internal Revenue Code and Treasury regulations, with experience or demonstrated familiarity with Sections 45X and/or 48E or related tax incentives.
• Experience analyzing tax-credit eligibility, tax structuring, tax risk, commercial agreements, or transactions involving tax attributes.
• Experience working with outside counsel and cross-functional legal, tax, finance, accounting, and business teams.
  
  

Preferred Skills

• Experience advising on Sections 45X and 48E.
• Familiarity with IRS guidance, tax-credit registration and reporting, substantiation requirements, and prevailing wage and apprenticeship rules where applicable.
• Experience supporting solar manufacturing, batteries, energy storage, renewable energy projects, or other energy and advanced manufacturing businesses.
• A practical, business-oriented lawyer with sound judgment and the ability to translate complex tax rules into clear commercial guidance.
• Collaborative, responsive, and comfortable working with internal business teams, outside advisors, and transaction counterparties.
• Strong communicator with excellent drafting, analytical, negotiation, and project-management skills.
• LL.M. in Taxation or equivalent specialized tax experience is a plus
  
  

Compensation

In accordance with applicable pay transparency laws, the anticipated annual base salary for this position is:

• Zone 1 (Bay Area, NYC): $184,900 – $277,400
• Zone 2 (CA, NJ, NY, DC): $169,500 – $254,300
• Zone 3 (All Others):$154,100 – $231,200
  
  

The applicable salary range is based on the employee’s primary work location. Individual compensation will be determined based on qualifications, relevant experience, education, skills, internal equity, and other business-related factors.

Hanwha Q CELLS America Inc. (“HQCA”) is a Qcells company, one of the world’s largest manufacturers and providers of solar photovoltaic (PV) products and solutions.  Headquartered in Irvine, California, HQCA has been rapidly expanding its business in North America through the expansion of products and solutions, including distributed energy solutions, direct-to-homeowner solar sales and financing, and EPC services.  We provide an opportunity to be part of an exciting and growing world-class global business in an interesting and expanding industry of the future.

Physical, Mental & Environmental Demands

To comply with the Rehabilitation Act of 1973 the essential physical, mental and environmental requirements for this job are listed below. These are requirements normally expected to perform regular job duties. Incumbent must be able to successfully perform all of the functions of the job with or without reasonable accommodation.

Mobility

Standing

20% of time

Sitting

70% of time

Walking

10% of time

Strength

Pulling

up to 10 Pounds

Pushing

up to 10 Pounds

Carrying

up to 10 Pounds

Lifting

up to 10 Pounds

Dexterity (F = Frequently, O = Occasionally, N = Never)

Typing

F

Handling

F

Reaching

F

Agility (F = Frequently, O = Occasionally, N = Never)

Turning

F

Twisting

F

Bending

O

Crouching

O

Balancing

N

Climbing

N

Crawling

N

Kneeling

N

The salary range is required by the California Pay Transparency Act and may differ depending on the location of those candidates hired nationwide. Actual compensation is influenced by a wide array of factors including but not limited to, skill set, education, licenses and certifications, essential job duties and requirements, and the necessary experience relative to the job’s minimum qualifications.

• This target salary range is for CA positions only and should not be interpreted as an offer of compensation.
  
  

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