Tax Director, Strategy & Transactions

About the Team

OpenAI Finance is responsible for ensuring the organization is set up for success in pursuit of its mission. The Tax team is a vital part of OpenAI, ensuring compliance with tax laws and regulations while optimizing the company's tax position. We work closely with various departments to provide tax insights and strategies that support the company's growth and financial objectives.

About the Role

OpenAI is hiring a Tax Director to lead structuring on our most complex, high-impact transactions, including M&A, joint ventures, financings, and global reorganizations. You’ll work alongside senior leadership to architect and execute tax strategies that shape how OpenAI grows, scales, and partners around the world. This role requires deep technical expertise and a strong track record of navigating sophisticated deal environments. The ideal candidate will bring a highly specialized skill set and the ability to deliver impactful tax advice in high-stakes, fast-moving transactions.

This role is based in San Francisco, CA. We use a hybrid work model of 3 days in the office per week and offer relocation assistance to new employees.

In this role, you will:

• Lead the tax structuring and execution of complex domestic and cross-border M&A transactions, including joint ventures, acquisitions, divestitures, and reorganizations.

• Conduct and oversee tax due diligence for potential acquisitions and investments, identifying key risks and opportunities.

• Review, draft, and negotiate tax-related contractual provisions to ensure alignment with business objectives and to mitigate tax risks.

• Partner closely with legal, finance, and corporate development teams to develop and implement tax-efficient structures for transactions.

• Drive post-acquisition tax integration planning and execution to align acquired entities with OpenAI’s tax and legal structure.

• Advise on the tax aspects of financing arrangements, including intercompany funding, capital structure optimization, and third-party financings.

• Monitor and assess the impact of tax law changes on transactional strategy and structuring.

• Manage external advisors and collaborate with internal stakeholders to ensure accurate and timely tax input throughout the transaction lifecycle.

• Build scalable frameworks and processes to support a high volume of strategic transactions in a rapidly growing, global environment.

You might thrive in this role if you have:

• J.D. and strong academic credentials; LL.M. in Taxation a plus.

• 12+ years of progressive tax experience, including significant exposure to complex domestic and cross-border M&A transactions.

• Deep technical expertise in Subchapter C, partnership taxation, and the taxation of flow-through entities, including structuring of LLCs and joint ventures.

• Demonstrated success leading negotiations on high-stakes, fast-paced deal environments from structuring through integration.

• Significant experience advising on the tax implications of financing transactions and capital structures in a multinational context.

• Experience drafting and advocating on international and domestic tax policy positions, working with internal and external partners, engaging in constructive conversations with parties with different views to achieve a singular objective.

• Proven ability to distill complex tax concepts into clear, actionable advice for non-tax stakeholders, including executive leadership.

• Exceptional judgment, presence, and communication skills; comfortable operating at the most senior levels of the organization.

• Track record of building trust and credibility across legal, finance, and corporate development teams in high-growth, global businesses.

About OpenAI

OpenAI is an AI research and deployment company dedicated to ensuring that general-purpose artificial intelligence benefits all of humanity. We push the boundaries of the capabilities of AI systems and seek to safely deploy them to the world through our products. AI is an extremely powerful tool that must be created with safety and human needs at its core, and to achieve our mission, we must encompass and value the many different perspectives, voices, and experiences that form the full spectrum of humanity. 

We are an equal opportunity employer, and we do not discriminate on the basis of race, religion, color, national origin, sex, sexual orientation, age, veteran status, disability, genetic information, or other applicable legally protected characteristic.

For additional information, please see OpenAI’s Affirmative Action and Equal Employment Opportunity Policy Statement.

Qualified applicants with arrest or conviction records will be considered for employment in accordance with applicable law, including the San Francisco Fair Chance Ordinance, the Los Angeles County Fair Chance Ordinance for Employers, and the California Fair Chance Act. For unincorporated Los Angeles County workers: we reasonably believe that criminal history may have a direct, adverse and negative relationship with the following job duties, potentially resulting in the withdrawal of a conditional offer of employment: protect computer hardware entrusted to you from theft, loss or damage; return all computer hardware in your possession (including the data contained therein) upon termination of employment or end of assignment; and maintain the confidentiality of proprietary, confidential, and non-public information. In addition, job duties require access to secure and protected information technology systems and related data security obligations.

We are committed to providing reasonable accommodations to applicants with disabilities, and requests can be made via this link.

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