USADirector, US International Tax
3 нед. назад
USADirectorRemote
us international taxincome tax provisiontax compliancegilityforeign tax credit
Lead US international tax reporting and compliance for a global AI company, overseeing tax provisions and scale compliance processes.
Обязанности
- 's international footprint is expanding rapidly — new entities, new markets, and commercial arrangements of unusual scale and novelty. The Tax team is hiring its first dedicated leader for US international tax reporting and compliance, a role that owns the US international components of our global income tax provision and our US international compliance program end to end, reporting to our global provision lead.
- You will be the technical authority on how US international tax rules apply to a frontier AI company: modeling net CFC tested income (NCTI, formerly GILTI), the FDDEI (formerly FDII) deduction, BEAT, Subpart F, and foreign tax credits through the provision each quarter, and standing up a compliance process that scales with the company. This is a hands-on leadership role — you will build the calculations, the controls, and eventually the team, while partnering closely with Accounting, Treasury, Legal, and our Big 4 advisors.
- Own the US international components of the quarterly and annual worldwide income tax provision: NCTI/GILTI, Subpart F, FDDEI/FDII, BEAT, foreign tax credit computations, Section 861 expense allocation and apportionment, E&P and PTEP tracking
- Own outside basis difference analysis and indefinite reinvestment assertions under ASC 740-30, and US international aspects of valuation allowance and uncertain tax position assessments
- Design and operate SOX controls over the international provision process and support the financial statement audit with our external auditors
- Lead preparation and review of the US international tax return workpapers and forms — today Forms 5471, 8992, and 926, expanding to Forms 1118, 8858, 8865, 8991, and 8993 as the international footprint and tax profile grow — including elections, statements, and disclosures, working with our co-sourced Big 4 compliance provider
- Support US withholding tax compliance (Forms 1042/1042-S) and cross-border payment analysis
- Build a compliance calendar, data pipelines, and review procedures that keep pace with new entities and transactions; drive automation and tax technology adoption (including AI tooling)
- Assist the tax planning and M&A teams on modeling the US international tax consequences of new market entry, entity structuring, intercompany and transfer pricing arrangements, financing, and M&A — from diligence through integration
- Monitor and model legislative and regulatory developments (OBBBA implementation guidance, Pillar Two interaction with the US system) and model their provision and cash tax impacts for leadership
- Manage outside advisors, support audit defense and controversy on US international issues, and mentor and develop tax team members
Требования
- Have substantial US international tax experience serving or working in multinational software and technology companies, with a combination of Big 4 public accounting and in-house corporate tax department experience
- Have deep technical command of US international tax law — NCTI/GILTI, Subpart F, FDDEI/FDII, BEAT, foreign tax credits, E&P/PTEP, Section 861 allocation — and of ASC 740 as it applies to those items, including ASC 740-30 outside basis analysis
- Have owned both the provision and the compliance sides of a US international tax function at scale, including reviewer-level command of Forms 5471, 8858, 8865, 1118, 8991, 8992, and 8993
- Hold a CPA and/or JD; a Master's in Taxation or LLM is a plus
- Communicate complex technical positions clearly to auditors, executives, and non-tax partners, and are comfortable being the sole authority on your domain
- Thrive in a high-growth, high-ambiguity environment where the fact pattern is often novel and the process has to be built, not inherited
Будет плюсом
- Experience with Pillar Two data and modeling and its interaction with US rules
- Experience with the tax aspects of large, novel commercial arrangements — infrastructure and compute agreements, strategic investments, or complex equity structures
- Hands-on experience with tax technology and an interest in applying AI tools to tax workflows
- Pre-IPO readiness or public company reporting experience at a multinational software company
- M&A experience spanning diligence, structuring, purchase accounting, and post-close integration
- The annual compensation range for this role is listed below.
- For sales roles, the range provided is the role’s On Target Earnings ("OTE") range, meaning that the range includes both the sales commissions/sales bonuses target and annual base salary for the role.
Другое
- ’s mission is to create reliable, interpretable, and steerable AI systems. We want AI to be safe and beneficial for our users and for society as a whole. Our team is a quickly growing group of committed researchers, engineers, policy experts, and business leaders working together to build beneficial AI systems.
- Minimum education: Bachelor’s degree or an equivalent combination of education, training, and/or experience
- Required field of study: A field relevant to the role as demonstrated through coursework, training, or professional experience
- Minimum years of experience: Years of experience required will correlate with the internal job level requirements for the position
- Location-based hybrid policy: Currently, we expect all staff to be in one of our offices at least 25% of the time. However, some roles may require more time in our offices.
- Visa sponsorship: We do sponsor visas! However, we aren't able to successfully sponsor visas for every role and every candidate. But if we make you an offer, we will make every reasonable effort to get you a visa, and we retain an immigration lawyer to help with this.
- We encourage you to apply even if you do not believe you meet every single qualification. Not all strong candidates will meet every single qualification as listed. Research shows that people who identify as being from underrepresented groups are more prone to experiencing imposter syndrome and doubting the strength of their candidacy, so we urge you not to exclude yourself prematurely and to submit an application if you're interested in this work. We think AI systems like the ones we're building have enormous social and ethical implications. We think this makes representation even more important, and we strive to include a range of diverse perspectives on our team. Your safety matters to us. To protect yourself from potential scams, remember that recruiters only contact you
- We believe that the highest-impact AI research will be big science. At we work as a single cohesive team on just a few large-scale research efforts. And we value impact — advancing our long-term goals of steerable, trustworthy AI — rather than work on smaller and more specific puzzles. We view AI research as an empirical science, which has as much in common with physics and biology as with traditional efforts in computer science. We're an extremely collaborative group, and we host frequent research discussions to ensure that we are pursuing the highest-impact work at any given time. As such, we greatly value communication skills.
- The easiest way to understand our research directions is to read our recent research. This research continues many of the directions our team worked on prior to , including: GPT-3, Circuit-Based Interpretability, Multimodal Neurons, Scaling Laws, AI & Compute, Concrete Problems in AI Safety, and Learning from Human Preferences.
- is a public benefit corporation headquartered in San Francisco. We offer competitive compensation and benefits, optional equity donation matching, generous vacation and parental leave, flexible working hours, and a lovely office space in which to collaborate with colleagues. Guidance on Candidates' AI Usage: Learn about our policy for using AI in our application process.