Senior Manager, Infrastructure Tax
Own day-to-day tax execution for major datacenter and infrastructure transactions, including deal modeling, entity structuring, transfer pricing, and tax provision coordination. Requires a JD or CPA, cross-border tax experience, and 8–10 years of relevant experience preferred.
About the job
Responsibilities
- Run intake for individual infrastructure transactions, gather site, counterparty, commercial, and timing facts, and prepare structure reviews and term-sheet input.
- Analyze service-versus-lease characterization, entity structures, and contract tax provisions; escalate judgment calls appropriately.
- Build and maintain after-tax deal economics models covering bonus depreciation, NOL utilization, and scenario analysis.
- Prepare tax inputs for Technical Accounting on lease-versus-purchase treatment, consolidation, capitalization policy, and book-tax differences.
- Execute datacenter entity structures across jurisdictions, including formation, operationalization, documentation, cross-border financing withholding, permanent establishment analysis, and debt-versus-equity characterization.
- Support transfer pricing for the infrastructure footprint, including intercompany compute pricing documentation and benchmarking.
- Prepare quarterly inputs for tax provision teams on new structures and deferred tax positions.
- Maintain infrastructure tax playbooks, issue-spotting checklists, and deal trackers.
Requirements
- JD or CPA required; LL.M. in Taxation or MST preferred.
- Experience supporting entity structures across multiple jurisdictions and collaborating with local finance, legal, and accounting teams.
- Working knowledge of cross-border withholding, permanent establishment analysis, and debt-versus-equity characterization.
- Experience owning discrete workstreams on capital-intensive deals from intake through post-close with limited supervision.
- Ability to manage multiple deals and collaborate across Legal, Accounting, FP&A, and business teams.
- Strong written and verbal communication skills.
- Comfort working in ambiguous, fast-moving environments.
Nice-to-haves
- 8–10 years of tax experience, including datacenter or infrastructure tax planning and international work.
- Big Four or law firm experience in a datacenter or infrastructure tax practice.
- In-house tax experience at a hyperscaler, cloud provider, or large-scale datacenter operator.
- Transfer pricing experience for intercompany services or compute, including benchmarking and documentation.
- Experience with construction-period capitalization, placed-in-service timing, property tax during buildout, and sales and use tax on construction inputs and operating equipment.
- Experience with non-US datacenter tax regimes and cross-border infrastructure structures.
Compensation
- Annual salary: $180,000–$230,000 USD.
- Hybrid policy: staff are expected to work from an office at least 25% of the time.
Skills
Tax Planning, Entity Structuring, Transfer Pricing, Bonus Depreciation, Nol Utilization, Permanent Establishment, Withholding Tax, Debt-Equity Analysis, Technical Accounting, FP&A, Deferred Tax, Datacenter Tax
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