# Director, US International Tax Planning

**Company:** [Anthropic](https://hotfix.jobs/companies/anthropic)
**Location:** Remote
**Role:** Finance & Accounting
**Salary:** $230k – $300k/yr
**Experience:** 10+ years
**Skills:** Us International Tax, Subpart F, Ncti, Beat, Foreign Tax Credits, Subchapter C, Transfer Pricing, Asc 740, Tax Modeling, Tax Planning, Pillar Two, Fddei, Partnership Tax, Internal Revenue Code
**Posted:** 2026-09-01

> Leads complex US international tax planning, modeling, documentation, and implementation across entities, transactions, and cross-border arrangements. Requires deep international tax expertise, end-to-end project leadership, and collaboration with M&A, Legal, Accounting, Treasury, and transfer pricing teams.

## Job Description

## Responsibilities
- Lead US international tax planning projects from analysis through implementation and help prioritize the planning group’s work.
- Analyze tax consequences of new entities and jurisdictions, intercompany arrangements, funding and repatriation, and cross-border commercial and compute agreements; recommend appropriate structures.
- Perform and review technical analyses under Subpart F, NCTI, BEAT, foreign tax credit, expense allocation, and apportionment rules.
- Apply Subchapter C to entity formations, contributions, distributions, liquidations, and internal reorganizations, including earnings and profits and stock basis analysis.
- Define assumptions and scenarios for models measuring cash-tax and effective-tax-rate impacts; review models for technical accuracy and own the resulting conclusions.
- Support post-closing M&A integration through step plans, alternative modeling, and follow-on planning.
- Draft technical memoranda and maintain examination-supporting documentation; coordinate with the provision team on ASC 740 and uncertain tax positions.
- Partner with compliance and transfer pricing teams on intercompany pricing, tax provision, and US international filings, including Forms 5471, 8858, 8991, 8992, and 1118.
- Scope, budget, and manage outside advisors and review their deliverables.
- Track US legislative, regulatory, and OECD developments and communicate impacts to Finance leadership.
- Coordinate with Tax, Legal, Accounting, and Treasury to implement approved planning and integration steps, including intercompany agreements.
- Support IRS and other tax-authority inquiries.

## Requirements
- Deep technical knowledge of US international tax provisions, including Subpart F, NCTI, BEAT, and foreign tax credits, with planning experience.
- Working knowledge of Subchapter C for multinational groups, including earnings and profits, stock basis, distributions, and internal reorganizations.
- Experience leading tax planning projects end to end: scoping, analysis, modeling, documentation, and implementation.
- Understanding of how planning positions affect transfer pricing, ASC 740, and US international compliance forms.
- Ability to research the Internal Revenue Code, regulations, and administrative guidance and write well-supported memoranda.
- Ability to review tax models, identify incorrect assumptions or mechanics, and explain required changes.
- Experience managing outside advisors, budgets, and deliverables.
- Ability to manage multiple concurrent projects and make defensible recommendations amid uncertainty.
- Strong communication and cross-functional collaboration skills with Legal, Accounting, and Treasury.
- Bachelor’s degree or equivalent combination of education, training, and experience.

## Preferred Qualifications
- CPA, JD, or LLM in taxation.
- 10–15 years of extensive US international tax experience, including public accounting, law firm, and/or in-house multinational technology experience.
- Post-acquisition integration planning experience, including step plans and modeling.
- Experience with transfer pricing, Pillar Two, FDDEI, partnership tax, and non-US tax rules.
- Experience with cross-border cloud, compute, licensing, infrastructure, data-center, energy, joint-venture, or financing structures.
- Experience supporting IRS examinations of international positions.
- Experience scaling or building an international structure at a high-growth company.
- Experience building or reviewing US international tax models.
- Experience using Claude or similar tools for tax research, modeling, or documentation.
- Experience mentoring or developing tax professionals.

## Compensation
- Annual salary: **$230,000–$300,000 USD**.

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