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OpenAIOpenAI

Tax Director, Business Advisory and Strategic Finance

The Tax Director will advise Finance, Legal, Product, Infrastructure, Treasury, and commercial teams on tax strategy for financing, infrastructure, products, contracts, and international expansion. The role requires a J.D. and 12+ years of progressive tax experience, along with broad commercial, transactional, and international tax expertise.

About the job

Responsibilities

  • Serve as a senior tax business partner to Finance, Legal, Infrastructure, Treasury, Accounting, Product, and commercial teams.
  • Advise on strategic business decisions, product development, commercial models, infrastructure investments, financing initiatives, and international growth.
  • Lead tax advice for complex commercial, infrastructure, and financing arrangements, evaluating tax and economic trade-offs and translating recommendations into practical structures and contractual positions.
  • Model tax and economic outcomes for commercial and financing arrangements, considering cost, flexibility, accounting treatment, risk, and speed.
  • Advise on structured finance and capital markets transactions, including debt and equity financings, credit facilities, asset-backed arrangements, third-party financing, intercompany funding, and bespoke financing structures.
  • Partner with commercial and legal teams on compute and infrastructure agreements, customer arrangements, technology and IP agreements, supply agreements, and strategic partnerships.
  • Translate tax considerations into contracting positions involving payment characterization, pricing, ownership, withholding, gross-ups, indemnities, tax responsibilities, and information rights.
  • Advise Product and commercial teams on product launches, pricing and monetization models, distribution channels, customer offerings, and new revenue streams.
  • Support international expansion through advice on market entry, legal entity structures, operating models, customer contracting, cross-border flows, intercompany arrangements, and regional operations.
  • Evaluate permanent establishment, withholding, transfer pricing, income characterization, and other cross-border considerations.
  • Monitor tax law, regulatory, and financial market developments and assess their implications for products, transactions, financing strategy, and operating models.
  • Build contracting guidelines, product advisory frameworks, standard tax positions, decision tools, and escalation protocols.
  • Manage external advisors and coordinate across internal tax specialties.
  • Communicate complex tax, financial, and commercial issues clearly to senior leaders and non-tax stakeholders.

Requirements

  • J.D. with 12+ years of progressive tax experience; an LL.M. in Taxation is a plus.
  • Broad tax expertise across commercial, product, financing, and international business matters.
  • Significant experience with structured finance, capital markets, corporate finance, or complex financing transactions.
  • Strong understanding of tax considerations for debt and equity instruments, credit arrangements, leases, asset financings, derivatives, hedging, and other financial products.
  • Experience reviewing and negotiating complex commercial agreements and converting technical tax issues into workable contractual solutions.
  • Experience advising on new offerings, pricing and revenue models, customer arrangements, and commercial scaling.
  • Experience supporting international expansion, market entry, cross-border operating models, and global commercial arrangements.
  • Experience advising on large-scale infrastructure, energy, technology, or other capital-intensive arrangements.
  • Strong financial and commercial acumen, including transaction economics, financial models, accounting implications, and contractual risk allocation.
  • Experience using AI tools for tax research, transaction analysis, knowledge management, and business advisory.
  • Intellectual curiosity, sound judgment, and comfort operating in ambiguous areas without established precedent.
  • Ability to distill complex tax, financial, and commercial issues into clear recommendations.
  • Exceptional communication and influencing skills with senior stakeholders.
  • Track record of collaborating across Finance, Legal, Infrastructure, Treasury, Accounting, Product, and commercial teams.

Nice to Have

  • LL.M. in Taxation.
  • Experience with compute, data centers, digital infrastructure, or long-term capacity agreements.
  • Experience developing AI-enabled workflows for tax functions.

Compensation and Benefits

  • Relocation assistance is offered.

Skills

Structured Finance, Capital Markets, Corporate Finance, Transfer Pricing, Withholding Tax, Tax Modeling, Commercial Contracts, International Tax, Financial Models, Derivatives, Hedging, Artificial Intelligence, Data Centers, Intercompany Funding, Accounting

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