This market intelligence briefing explores where corporate tax hiring is accelerating – and where it is holding steady – as tax functions respond to a more complex but increasingly stable legislative environment. Based on Mary’s discussions with senior in‑house tax leaders, it shows that hiring in 2026 is highly selective, with strongest demand for senior international tax specialists with GILTI and FDII expertise, tax technology leaders and tax controversy professionals, while general compliance, SALT and mid‑level roles move more slowly. The article provides clear guidance for hiring managers and candidates on where urgency exists, how the in‑house tax function is evolving, and why decisive hiring is becoming a critical advantage.
Most conversations I have with tax leaders right now follow a familiar pattern: there’s acknowledgment that the environment is genuinely complex, a sense that the team is stretched, and then a pause before the real question surfaces: should we be hiring, or is this the wrong moment?
The honest answer is: it depends on what you’re hiring for. And that nuance is exactly what this briefing is about.
Across my conversations with tax directors, VPs of Tax, and CFOs at multinational and financial services firms, a clear picture is emerging – this is not a market where everyone is growing or everyone is frozen. Rather, it is a market of selective, purposeful growth, concentrated in specific specialisms, driven by specific pressures, and moving faster than many hiring managers expect.
Three legislative and regulatory shifts are doing most of the heavy lifting in 2026, which I will briefly explain.
1. The One Big Beautiful Bill Act (OBBBA) and its business tax provisions
The OBBBA, signed into law in July 2025, has reset the planning horizon for most large US corporates. Permanent revival of 100% bonus depreciation, changes to Section 162(m) controlled group rules, and a new floor on corporate charitable deductions have all landed simultaneously, each requiring expert interpretation and implementation inside the business, not just outside counsel guidance.
The practical effect of this is that companies that had been running lean on the assumption that tax law would remain in flux are now facing a stable but genuinely complex environment that rewards having the right expertise in-house.
2. Global Intangible Low-Taxed Income (GILTI) and Foreign-derived intangible income (FDII) changes effective 2026
For multinationals, the stakes just got higher. The removal of the GILTI deemed tangible income return element, combined with changes to the Section 250 deduction percentages for both GILTI and FDII, has materially shifted effective tax rates on international structures. The new effective rate on qualifying FDII income sits at approximately 14%.
These are not theoretical adjustments. They require active modeling, restructuring analysis, and ongoing compliance. Generalist tax teams are simply not positioned to absorb that work without specialist support.
3. Tax controversy is rising
IRS audit activity has been picking up across large corporates, and the combination of legislative complexity and heightened scrutiny is creating genuine exposure. Companies that have historically managed controversy through outside counsel are now reconsidering whether they need that capability sitting inside the business: someone who knows the company’s history, its positions, and its risk tolerance.
Where hiring is accelerating
As demand rebounds across the market, three specialisms are emerging as clear hotspots for accelerated hiring.
1. International tax: GILTI/FDII specialists
This is the clearest signal in the market right now. Demand for international tax professionals who can navigate the post-OBBBA GILTI/FDII landscape is outpacing supply by a significant margin. Companies are not just looking for technical knowledge; they are looking for people who can translate complex international structures into business decisions the CFO can act on.
The profile that is moving fastest: a Director or Senior Manager level professional with 8-12 years of experience, strong transfer pricing fluency, and ideally exposure to both Big 4 and in-house environments. These candidates are rare, know their value, and are not applying to job postings.
2. Tax technology and automation
The bifurcation of the tax career path is playing out in real time in hiring decisions. Tax leaders are increasingly separating the “technologist” role from the “strategic advisor” role and building for both simultaneously rather than searching for a unicorn who can do everything.
Tax technology professionals who can work across ERP systems, tax provision software, and increasingly AI-powered compliance tools are in genuine demand. This is not a niche role anymore; it is becoming a standard component of any well-built in-house tax function at a multinational or large financial services firm.
3. Tax controversy and audit defense
The third accelerating area is one that often gets overlooked in hiring conversations because it feels reactive rather than strategic. But the companies I am speaking with are recognizing that controversy capability is a strategic asset, not just a cost center.
Demand is concentrated at the senior end, typically VP or Director of Tax Controversy, and the candidate pool is tight. Former IRS agents, Big 4 controversy specialists, and in-house professionals with direct audit defense experience are all fielding multiple conversations simultaneously.
Where hiring is holding steady
Not every function is in growth mode. SALT (state and local tax) hiring, while steady, is not showing the urgency of the three areas above. Transfer pricing roles at the mid-level are moving more slowly than international tax overall, partly because the immediate GILTI/FDII pressure is concentrated at the senior end.
General tax compliance roles at the Manager level are also seeing slower movement. The efficiency gains from automation are being felt here first. Companies are not replacing attrition at the same rate they were two years ago, and in some cases are explicitly restructuring teams to reduce headcount at the compliance layer while adding at the specialist and strategic layers.
This does not mean these roles are disappearing. It means the market has a clear hierarchy of urgency right now, and tax leaders who understand that hierarchy will move faster and more decisively on the hires that matter most.
Hiring managers
Candidates
The companies that will have the right tax teams in place twelve months from now are making those hiring decisions today, not waiting for certainty that never fully arrives.
The 2026 in-house tax market rewards decisiveness. The legislative environment has stabilized enough to plan. The talent market is tight enough that waiting costs you real options. And the function itself is evolving fast enough that the right hire today looks different from the right hire two years ago.
If you would like to talk through what this means for your team or your own career, I am always happy to have that conversation directly.
Pure Search is a specialised global search and recruitment firm that focuses on identifying leading talent across corporate governance functions: Audit, Compliance, Legal, Risk, Finance and Tax.
If you’d like to have a conversation about your function, please get in touch.
