M&A Tax Director

2 нед. назад

USADirectorRemote

tax planningm&acorporate financetransaction structuring

Lead and manage tax workstreams for acquisitions and strategic transactions at .

Обязанности

We are looking for an M&A Tax Director to join our Tax Team at . As the company pursues an active and growing pipeline of acquisitions, acqui-hires, data center investments, joint ventures and other strategic transactions, this role will be a core member of our transactions tax function, working closely with our M&A Tax Lead. You will support and lead tax workstreams across the deal lifecycle, from initial evaluation through post-closing integration, and serve as a trusted resource for our Corporate Development, Legal, and Finance teams. Beyond transactions, this role will support a wide range of strategic and operational tax matters. This is a high-impact role with significant ownership and a front-row seat to some of the most consequential transactions and tax planning w
Lead and manage tax workstreams for acquisitions, mergers, acqui-hires, asset and stock purchases, corporate reorganizations, financing transactions, and minority investments, including tax due diligence, risk identification and quantification, and deal structuring analysis
Partner with Corporate Development on deal pipeline evaluation, providing early-stage tax input to inform go/no-go decisions and deal economics
Draft and review tax provisions in transaction documents, including purchase agreements, merger agreements, and ancillary deal documents
Support post-acquisition tax integration planning, including entity rationalization, intercompany restructuring, and tax attribute analysis
Advise on tax considerations for data center investments, build-to-suit arrangements, leases, and related infrastructure transactions, and coordinate with relevant team members on incentives, credits, and indirect tax matters
Advise on the tax structuring of joint ventures, strategic partnerships, and REIT-related investment structures, including real estate and data center joint venture arrangements
Help build and maintain transactions tax playbooks, due diligence checklists, and internal processes
Coordinate with the tax compliance and provision teams to ensure clean handoff of closed transactions, including documentation of structure, elections, tax attributes, and reporting positions
Prepare technical tax memoranda documenting transactions, material tax positions, and risk assessments to support internal sign-off, financial statement audit, and tax return filing positions

Требования

JD or CPA
M&A and transactional tax experience gained at a large law firm, Big 4 M&A tax practice, or in-house transactions tax team
Strong technical expertise in federal and state tax rules governing corporate transactions, including Section 338, Section 368 reorganizations, and asset and stock acquisitions
Experience running tax due diligence workstreams and quantifying tax exposures in transaction contexts
Experience drafting and negotiating tax provisions in M&A transaction documents
Experience supporting post-acquisition integration from a tax perspective, including entity rationalization and intercompany restructuring

Будет плюсом

7-10 years of tax experience, with significant M&A and transactional tax exposure
LL.M. in Taxation or MST
Experience providing general tax advisory support, including advising on commercial contracts, operational matters, and cross-functional tax questions
Experience with joint ventures, partnerships, minority investments, revenue-sharing arrangements and financing transactions
Experience with REITs, including REIT qualification and tax considerations for REIT joint ventures and real estate investment structures
Experience with data center acquisitions, infrastructure transactions, or real estate tax considerations
Tax experience at a high-growth technology company
Knowledge of state and local tax (SALT) implications of transactions
Experience with equity compensation tax issues in the context of acquisitions and acqui-hires
Exposure to international tax aspects of cross-border acquisitions
Exceptional communication skills, with the ability to translate complex tax issues into clear, actionable guidance for Legal, Finance, and Corporate Development partners
Comfort with ambiguity and a willingness to help build processes from scratch in fast-paced environments
Passion for 's mission to build safe, transformative AI systems
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.