# Tax Director, Business Advisory and Strategic Finance

**Company:** [OpenAI](https://hotfix.jobs/companies/openai)
**Location:** San Francisco, CA
**Role:** Finance & Accounting
**Salary:** $347k – $385k/yr
**Experience:** 12+ years
**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
**Posted:** 2026-08-19

> 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.

## Job Description

## 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.

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