Practice Areas · Tax · International Tax
International Tax Recruiters
Specialist search for international tax lawyers — partners, counsel, and in-house tax leaders whose work is a second tax system, a treaty, or a related-party price. Demand is dated public record: the OECD count, the IRS advance-pricing report, and Public Law 119-21.
›50 qualified domestic minimum taxes, 18 May 2026
An international tax lawyer recruiter places partners, counsel, and in-house tax leaders on cross-border work. Sartori & Partners has run 17 international tax searches since 2023. On 18 May 2026 the OECD reported 50 jurisdictions with a qualified domestic minimum top-up tax. IRS Announcement 2026-08, dated 30 March 2026, reports 110 advance pricing agreements executed in 2025. Public Law 119-21, signed 4 July 2025, sets a 40 percent GILTI deduction for years beginning after 31 December 2025. A NYSE-listed industrial in Houston hired a director of international tax in 14 weeks in 2025.
Inside the international tax market.
The figures in this section are public records with a date and a publisher. They describe the work that creates the seat. They are not a headcount of international tax lawyers.
- 50
- Jurisdictions that have completed qualification for a domestic minimum top-up tax and the QDMTT safe harbour.
- OECD announcement, 18 May 2026
- 110
- US advance pricing agreements executed in calendar 2025, from 178 applications filed that year.
- IRS Announcement 2026-08, 30 March 2026
- 2,731
- Mutual agreement procedure cases started in 2024, of which 1,265 were transfer-pricing cases.
- OECD 2024 MAP statistics, released 31 October 2025
International tax is the part of a tax practice that cannot be done inside one statute. The file is a controlled foreign corporation, a foreign tax credit, a treaty article, or the price charged between related parties. A lawyer who plans those positions and a lawyer who defends them in an examination can sit in the same group and still be the wrong hire for each other. Sartori & Partners has run 17 international tax searches since 2023, across law-firm lateral seats and in-house seats. That count is the working file for this specialism. The published firm book is separate: 400+ placements since 2017 (230+ in-house), of which 52 are general counsel and chief legal officer searches.
There is no official census of the specialty. The Bureau of Labor Statistics’ Occupational Outlook Handbook reports that lawyers held about 863,700 jobs in 2025, and that the median annual wage was $159,670 in May 2025. The Handbook names tax lawyers as a specialty, including work for the Internal Revenue Service, and it does not publish an international-tax employment figure. A search that starts from a borrowed headcount is guessing. A hiring partner or a head of tax can read the dated records instead.
Low mobility is the other constraint, and it is the subject of the market note Tax lawyers: low mobility, high market value. People who can sign a cross-border return are often already inside a group that will not release them for a lateral conversation. A posted role reaches lawyers who are looking. A retained search is the route to lawyers who are not.
Live tax roles.
These openings are tagged to the tax practice. They are not filtered to international tax alone.
What is creating the seats in 2026.
Three public clocks are running at once: the global minimum tax, the 2025 US international reforms, and a dispute inventory measured in years.
Global minimum tax. On 18 May 2026 the OECD said the central record of the global minimum tax now shows that 44 jurisdictions have completed the transitional qualification process for their income inclusion rule, and that 50 jurisdictions have completed it for their domestic minimum top-up tax and the QDMTT safe harbour. The same release says 37 jurisdictions have implemented a qualified income inclusion rule, a qualified domestic minimum top-up tax, or both, applying to in-scope multinational groups as of their 2024 reporting fiscal year. Jurisdictions that implemented the rules from 2024 agreed to publish a list of places expected to have a fully operational GloBE Information Return filing portal by 31 May 2026, and to use mechanisms in domestic law to waive penalties or suspend enforcement of a local filing where the return was filed centrally in a jurisdiction on that list.
That is a staffing fact, not a conference topic. A group that is in scope needs someone who can build and sign the return. A law firm that advises those groups needs associates who have done the calculation. A partner who can describe the model rules and has not lived a filing season is a different profile, and the requisition should say which one it is buying.
United States, Public Law 119-21. The statute was signed on 4 July 2025. The Congressional Research Service’s In Focus IF13069 states that the international changes to the GILTI and FDII deductions are effective for tax years beginning after 31 December 2025. CRS states that the law reduces the GILTI deduction from 50 percent to 40 percent and the FDII deduction from 37.5 percent to 33.34 percent, makes those deductions permanent, and eliminates the 10 percent tangible-asset reduction. At the 21 percent corporate rate, CRS states that the prior deductions produced 10.5 percent for GILTI (scheduled to rise to 13.125 percent after 2025) and 13.125 percent for FDII (scheduled to rise to 16.4 percent after 2025). The new permanent deductions, CRS states, produce 12.6 percent for GILTI and 14 percent for FDII. The statute’s headings rename the regimes net CFC tested income and foreign-derived deduction eligible income.
A 2026 brief that still describes the seat as “GILTI at 10.5 percent” is describing prior law. The person who can recompute tested income under the new deduction, drop the tangible-asset reduction, and explain the result to a CFO is the hire. The person who last touched the regime in 2018 needs a different conversation, and often a different role.
Disputes, not just filings. The OECD released 2024 mutual agreement procedure statistics on 31 October 2025, covering 141 jurisdictions. Under the post-2016 method that removes double counting, 2,731 cases started in 2024. Of those, 1,265 were transfer-pricing cases — attribution and allocation — and 1,466 were other cases. Average resolution time for transfer-pricing cases was 30.9 months, down from 32 months in 2023. The same release says 80 jurisdictions reported allowing bilateral advance pricing arrangements, up from 73 in 2023, and that the average time to grant an APA rose to 39.6 months in 2024, from 36.8 months in 2023.
The US figures use two calendars, and they should not be added together. IRS Announcement 2026-08, issued 30 March 2026, is the calendar-year report for the Advance Pricing and Mutual Agreement Program. In 2025 the program received 178 APA applications — 23 unilateral, 153 bilateral, and 2 multilateral — and executed 110 agreements — 14 unilateral, 90 bilateral, and 6 multilateral. Pending requests stood at 622 on 31 December 2025. The IRS Data Book 2025, Publication 55-B, published April 2026, reports fiscal year 2025, which runs from 1 October 2024 through 30 September 2025: 144 advance pricing agreements executed, 79.9 percent of them bilateral. A board memo that quotes 110 and 144 as if they were the same year is mixing a calendar year with a fiscal year.
A planning hire and a controversy hire are not interchangeable on that clock. An APA measured in multiple years is a different seat from a minimum-tax calculation that has to go out with the return. The controversy map is tax controversy and transfer-pricing disputes counsel. International tax is the practice those disputes sit inside.
Four buyers, four different seats.
The same résumé word, international tax, covers a law-firm partner search and a company’s first transfer-pricing counsel. The buyer decides which search it is.
Law firms
International tax groups hiring a lateral partner, counsel, or senior associate. The gating questions are conflicts and whether the book actually travels.
See this searchCompanies
A head of tax, a CFO, or a general counsel hiring a director of international tax or transfer-pricing counsel onto the employed tax function.
See this searchSponsors and funds
Private-equity and fund platforms whose portfolio companies or blocker structures produce CFC inclusions, treaty positions, or a cross-border deal tax file.
See this searchDispute seats
Teams staffing an examination, an advance pricing agreement, or a mutual agreement procedure. That hire is not a substitute for the person who files the return.
See this searchLaw-firm searches turn on conflicts and on whether any client relationships move with the lawyer. A partner whose cross-border work is captive to one platform’s fund clients may have nothing portable. A counsel or senior associate is hired for the matters they have already staffed: CFC inclusions, foreign tax credit limitation, treaty claims, or a transfer-pricing method they can defend. Keyword overlap with “international” on a domestic M&A tax résumé is not that record. Lateral partner moves are run as partner recruiting. Associate and counsel moves are run as associate recruiting.
Company searches are usually opened by a head of tax or a chief financial officer, sometimes with the general counsel as the sponsor and sometimes without. The title may be director of international tax, international tax counsel, or transfer-pricing counsel. Writing the requisition as a deputy general counsel pulls a different pool: lawyers whose last decade was corporate advice, not a provision and a return. In-house mandates are run as in-house counsel recruiting. Where the company is hiring its first general counsel rather than a tax specialist, that is a different search, with the published GC clock of 24 days to shortlist and 11 weeks median to an accepted offer across 52 general counsel and chief legal officer searches since 2017.
Sponsor and fund searches sit between those two. The lawyer may join the sponsor, the fund, or a portfolio company. The work is deal tax with a cross-border file: blocker vehicles, CFC status after an acquisition, a treaty claim on the exit. It is not a stand-alone controversy practice, and it is not a generalist M&A seat with a tax reviewer added at the end. The parent tax practice is the wider map. International tax is the cross-border slice of that practice.
Dispute seats are the fourth buyer. The OECD’s 30.9-month average for transfer-pricing mutual agreement procedure cases closed in 2024 is the outside clock. A company that needs someone in the examination this quarter, and a company that needs someone to live with an APA for several years, should not share a job description. Domestic penalty controversy, without a treaty or a related-party price, belongs on tax planning and controversy.
Three published bands. None of them is “international tax pay.”
Price the desk you are hiring. Lockstep, in-house counsel, and a general counsel’s total pay are different objects.
Bloomberg Law reported on 2 June 2026 that Milbank raised associate base salaries by $10,000 to $20,000 by class year and that McDermott matched, taking the scale from $235,000 to $455,000, effective 1 July 2026. That is the lockstep base a tax associate at a matching firm is compared with. It is not an in-house offer, and it is not partner compensation. Year-end bonus grids are a separate vintage. The comparison, including what not to add together, is on tax attorney salary 2026.
The Association of Corporate Counsel’s 2025 Law Department Compensation Survey, Executive Summary dated 16 September 2025, puts US in-house Attorney median base at $148,000 and Senior Attorney median base at $201,000. The survey ranks tax among specialties and does not print a tax-specialty dollar. Using either median as “the international tax number” invents a figure the survey withheld. Partner cash is a third object again: draws and profits, not the associate scale. The firm-wide partner pages are law firm partner salary 2026 and equity partner salary 2026.
A general counsel total-pay figure is the wrong benchmark for a director of international tax. Sartori & Partners’ analysis of 2026 proxy filings puts median total compensation at $4.76 million for sitting general counsel who are named executive officers at 236 of the largest US-listed companies. That median is total pay for those named officers. It is not base salary, and it is not a tax-director band. The series lives on general counsel salary 2026. A company that copies it onto an international tax requisition will clear every serious candidate out of the process, or will hire someone who expected a different job.
Part of the tax practice, not a duplicate of it.
International tax sits inside tax. The neighboring specialism is tax planning and controversy. The two overlap and they are not the same search.
Tax
The full US tax map: planning, controversy, and the city pages under it.
Tax recruiters Sibling specialismTax Planning & Controversy
Structuring before close, and defense of the position under audit. Domestic controversy lives here.
Planning and controversyOpen an international tax search when the matter is cross-border: a CFC inclusion, a foreign tax credit, a treaty, Pillar Two, or a transfer-pricing method. Open tax planning and controversy when the matter is the plan and the fight inside one system, including domestic penalties and appeals. A group that needs both should say so at the start. One combined search produces a list of generalists and no one who can sign the actual file.
Where the cross-border tax work concentrates.
CFC, treaty, and transfer-pricing hiring in our tax work shows up most often in these four markets.
New York carries fund and capital-markets tax, including CFC and transfer-pricing work that travels with the deal. Washington carries the statute and the Service: lawyers who have sat with Treasury, the IRS, or the legislative process, and who now advise on the same rules from private practice or a company. Miami’s tax bar is shaped by inbound investment and information-reporting regimes that other US cities see less of. Houston’s is shaped by energy groups whose structures cross a border. A search that is truly national should say so. A search that is secretly one of these four should not be briefed as “US international tax, any city.”
One director hire, on this file.
The firm-wide general counsel clock is published. The international tax file is a separate count, and the Houston matter is one search inside it.
In 2025 a NYSE-listed industrial in Houston hired a director of international tax. The shortlist was ready in 22 days. The accepted offer came in 14 weeks. The search is one of 17 international tax searches since 2023. It is not one of the 52 general counsel and chief legal officer searches. Those run to a shortlist in 24 days and an accepted offer in a median of 11 weeks, with a range of 8 to 16.
The general counsel of that NYSE-listed industrial told us: We needed someone who had filed a GILTI return and sat through a transfer-pricing exam. The shortlist was that person, not a general tax partner with one cross-border slide.
The commercial terms are the firm’s, on every retained search. The fee is 25–30% of the hire’s total first-year compensation. Thirty percent of the fee is paid at engagement and kept if the client cancels. Replacement cover is 12 months on general counsel, chief legal officer, and chief compliance officer searches, and 6 months on other in-house searches. A director of international tax is in the second group. Offer acceptance on corporate mandates is 96%. Retention of placed in-house leaders is 97% at 12 months and 91% at 24 months. None of those rates is an international-tax-only statistic. They are the book the fee letter already uses.
The searches we run in international tax.
Law-firm and company mandates, from a confidential lateral partner move to an in-house director, each scoped to the cross-border file rather than to the word tax.
Lateral Partner & Practice-Group Moves
Confidential lateral partners and practice-group moves in international tax, assessed on portable cross-border work, conflicts, and platform fit.
Explore this search 02In-House & General Counsel
Directors of international tax, transfer-pricing counsel, and heads of tax who report to a CFO or a general counsel.
Explore this search 03Associate & Counsel Recruiting
Mid-level and senior associates and counsel who have built CFC, foreign-tax-credit, or transfer-pricing work, not a keyword match on “international.”
Explore this search 04Tax Controversy Seats
Counsel for examinations, advance pricing agreements, and mutual agreement procedure files, where the outside clock is measured in years.
Explore this searchThe records behind the dated figures.
- OECD, 18 May 2026 — 44 jurisdictions completed income-inclusion-rule qualification; 50 completed domestic minimum top-up tax and QDMTT safe-harbour qualification; 37 jurisdictions apply a qualified IIR and/or QDMTT to in-scope groups for the 2024 reporting year; GIR portal list expected by 31 May 2026.
- OECD, 31 October 2025 — 2024 MAP statistics cover 141 jurisdictions; transfer-pricing cases averaged 30.9 months (32 months in 2023); 80 jurisdictions allow bilateral APAs, up from 73; average time to grant an APA 39.6 months in 2024, from 36.8 in 2023.
- OECD 2024 MAP statistics dataset — 2,731 cases started in 2024 under the post-2016 method; 1,265 transfer-pricing cases and 1,466 other cases.
- Public Law 119-21, signed 4 July 2025 — headings for foreign-derived deduction eligible income and net CFC tested income.
- Congressional Research Service, In Focus IF13069 — GILTI deduction 50 percent to 40 percent (12.6 percent); FDII deduction 37.5 percent to 33.34 percent (14 percent); 10 percent tangible-asset reduction eliminated; prior-law GILTI 10.5 percent, scheduled to 13.125 percent, and prior-law FDII 13.125 percent, scheduled to 16.4 percent; effective for tax years beginning after 31 December 2025.
- IRS Announcement 2026-08, 30 March 2026 — calendar 2025: 178 APA applications (23 unilateral, 153 bilateral, 2 multilateral); 110 executed (14 unilateral, 90 bilateral, 6 multilateral); 622 pending on 31 December 2025.
- IRS Data Book 2025, Publication 55-B, April 2026 — fiscal year 2025: 144 APAs executed, 79.9 percent bilateral. Fiscal year, not calendar 2025.
- Bureau of Labor Statistics, Occupational Outlook Handbook, Lawyers — about 863,700 lawyer jobs in 2025; median annual wage $159,670 in May 2025. Tax is named. International tax is not counted.
- Bloomberg Law, 2 June 2026 — matching-firm associate base $235,000 to $455,000, effective 1 July 2026.
- ACC / Empsight, 2025 Law Department Compensation Survey, Executive Summary 16 September 2025 — Attorney median base $148,000; Senior Attorney median base $201,000. Not a tax-specialty dollar.
International tax recruitment — common questions
What does an international tax lawyer recruiter do?
An international tax lawyer recruiter places partners, counsel, and in-house tax leaders on cross-border work: controlled-foreign-corporation inclusions, foreign tax credits, treaties, and transfer pricing. Sartori & Partners has run 17 international tax searches since 2023. That file is not the firm-wide book of 400+ placements since 2017 (230+ in-house).
What is driving international tax hiring in 2026?
On 18 May 2026 the OECD reported 50 jurisdictions with a qualified domestic minimum top-up tax and 44 that have completed qualification for an income inclusion rule. Public Law 119-21, signed 4 July 2025, sets a 40 percent GILTI deduction for tax years beginning after 31 December 2025. The Congressional Research Service states that deduction produces a 12.6 percent rate. IRS Announcement 2026-08, dated 30 March 2026, reports 110 advance pricing agreements executed in calendar 2025.
Who hires an international tax lawyer?
Four buyers show up on these searches. Law firms hire lateral partners, counsel, and senior associates into an international tax group. Companies hire a director of international tax or transfer-pricing counsel, often reporting to the head of tax or the CFO rather than only to the general counsel. Sponsors hire for a fund or a portfolio company with a CFC or treaty file. Dispute seats hire for an examination, an advance pricing agreement, or a mutual agreement procedure. A domestic penalties lawyer is a different search, covered under tax planning and controversy.
How long does an international tax search take?
On general counsel and chief legal officer searches since 2017, the shortlist arrives in 24 days and the accepted offer in a median of 11 weeks, with a range of 8 to 16, across 38 searches. An international tax director is not that seat. A NYSE-listed industrial in Houston hired a director of international tax in 2025: shortlist in 22 days, accepted offer in 14 weeks. That file is one of 17 international tax searches since 2023.
What does an international tax lawyer earn in 2026?
There is no official international-tax salary. Bloomberg Law reported on 2 June 2026 that matching-firm associate base now runs $235,000 to $455,000, effective 1 July 2026. The Association of Corporate Counsel’s 16 September 2025 survey puts in-house Attorney median base at $148,000 and Senior Attorney at $201,000. Those are not tax-specialty dollars. The bands, and why a general-counsel total-pay figure does not price this seat, are on tax attorney salary 2026.
How is an international tax search paid?
Searches are retained only. The fee is 25–30% of the hire’s total first-year compensation. Thirty percent of the fee is paid at engagement and kept if the client cancels. General counsel, chief legal officer, and chief compliance officer searches carry a 12-month replacement term. Other in-house searches, including a director of international tax, carry 6 months. Offer acceptance on the corporate book is 96%. Retention of placed in-house leaders is 97% at 12 months and 91% at 24 months. Those rates are the firm book, not a separate international-tax rate.
International Tax
The right international tax hire begins with a quiet conversation.
Tell us the mandate — a lateral partner, a director of international tax, or a controversy seat — and we will tell you whether we are the right firm to run it. No obligation, complete discretion.