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Tax Principal, Business Advisory

300k – 370kSan Francisco, CAHybrid8+ YOE
Summary

Serve as strategic tax advisor and technical expert for a high-growth AI company, providing business-oriented guidance on transactions, international expansion, and complex tax issues while supporting audit defense and compliance.

About the role

Key Responsibilities

Business Advisory & Transaction Support

  • Serve as a strategic tax advisor to business, product, partnerships, and go-to-market teams on new initiatives, product launches, pricing and billing structures, and commercial arrangements
  • Provide practical, business-oriented tax guidance on strategic transactions, including infrastructure and compute arrangements
  • Review and negotiate tax provisions in commercial contracts, cloud service agreements, and partnership arrangements
  • Advise on the tax considerations of international expansion and new market entry
  • Collaborate with Legal, Finance, and business teams on cross-functional matters

Technical Research & Documentation

  • Research and document significant technical tax issues, including equity compensation and operational tax questions
  • Prepare comprehensive tax technical memoranda meeting rigorous audit standards
  • Conduct in-depth research on complex federal and international tax issues using primary sources (Code, regulations, case law, legislative history)
  • Draft technical memoranda supporting material tax positions and planning initiatives
  • Maintain tax technical research library and documentation standards

Tax Compliance & Risk Assessment

  • Partner with tax team members to assist with driving tax audit defense and dispute resolution efforts
  • Prepare audit defense files, coordinate responses to tax authority inquiries, and manage relationships during examinations and appeals processes
  • Assist with quarterly and annual tax provision processes (FIN 48/ASC 740 compliance)
  • Analyze and document uncertain tax positions and related reserves

Required Qualifications

  • JD or LLM in Taxation from an accredited law school
  • Exceptional tax technical research and writing skills
  • Deep expertise in US federal income tax research methodology and primary source materials
  • Experience preparing technical tax memoranda for audit or IRS defense purposes
  • Proven ability to translate complex tax technical concepts into clear, well-documented analysis and practical business guidance
  • Demonstrated success partnering with business teams as a strategic advisor
  • Meticulous attention to detail and commitment to technical excellence

Preferred Qualifications

  • 8–12 years of tax experience with significant Big 4 and/or large law firm background
  • Experience with tax technical software/databases (Bloomberg Tax, RIA Checkpoint, Westlaw)
  • Experience with equity compensation tax matters (Section 83, 409A, 422, etc.)
  • Knowledge of international tax matters (Subpart F, GILTI, transfer pricing, treaty analysis)
  • Experience in technology or AI/software industry
  • Prior in-house experience at a high-growth technology company
  • Familiarity with public company tax operations and reporting requirements
Skills
US federal income tax researchTax technical memorandaJD/LLM in TaxationBloomberg TaxRIA CheckpointWestlawSection 83Section 409ASection 422Subpart FGILTITransfer pricingTreaty analysisFIN 48ASC 740
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