Senior Manager, Infrastructure Tax

3 дн. назад

USASeniorRemote

tax analysisfinancial modelingdocumentationinternational taxtransfer pricingfp&alegal coordination

Manage day-to-day execution of infrastructure tax workstreams supporting AI compute investment portfolio.

Обязанности

is making significant, sustained investment in compute infrastructure to support our AI safety mission. We are looking for a Senior Manager, Infrastructure Tax to work alongside the Infrastructure Tax Lead on that portfolio. The Lead owns the integrated tax position across the portfolio. This role carries the day-to-day execution of it: running intake on individual deals, owning defined workstreams end to end, building the models and documentation, and coordinating the work across Legal, Technical Accounting, FP&A, International Tax, Transfer Pricing, and Provision.
This is a hands-on role for a tax practitioner who wants to own workstreams on one of 's largest capital commitments. It reports to the Infrastructure Tax Lead.
Run deal intake for individual infrastructure transactions: gather facts on site specs, counterparty structure, commercial terms, and timing; prepare the structure review and term-sheet input for the Lead's sign-off early enough to shape the deal
Analyze service versus lease characterization, entity structure, and contract tax provisions for assigned deals, working with the Tax Transactions and Tax Planning teams and escalating judgment calls to the Infra Tax Lead
Build and maintain the after-tax deal economics models: bonus depreciation on large-scale buildouts, NOL utilization, and scenario analysis; work with Tax Planning, Tax Operations, and Infrastructure Accounting so the tax assumptions in deal approval packages are accurate
Prepare the tax-side inputs for Technical Accounting on lease-versus-purchase treatment, consolidation questions, capitalization policy, and book-tax differences across deal structures
Execute on datacenter entity structures across jurisdictions under the Lead's direction: entity formation, operationalization with local teams, contemporaneous documentation, withholding on cross-border financing, permanent establishment analysis, and debt-versus-equity characterization
Support transfer pricing on the infrastructure footprint: gather the facts, maintain the documentation for intercompany compute pricing, and coordinate benchmarking
Prepare the quarterly inputs for the tax provision team on new structures and deferred tax positions so there are no surprises between deal close and quarter close
Draft and maintain infrastructure tax playbooks, issue-spotting checklists, and internal trackers, and keep them current as deals close

Требования

Experience supporting entity structures across multiple jurisdictions, including contemporaneous documentation and working with local finance, legal, and accounting teams
Working knowledge of cross-border withholding on intercompany and third-party financing, permanent establishment analysis, and debt-versus-equity characterization
A track record of owning discrete workstreams on capital-intensive deals from intake through post-close and carrying them to completion with limited supervision
The ability to work across Legal, Accounting, FP&A, and business teams, carry several deals in parallel, and know when to escalate
Strong written and verbal communication, including written analysis that a tax lead can review and sign off on quickly
Comfort with ambiguity and a fast-moving environment

Будет плюсом

8 to 10 years of tax experience with exposure to datacenter or infrastructure tax planning, including some international work
Big 4 or law firm experience in a datacenter or infrastructure tax practice
In-house tax experience at a hyperscaler, cloud provider, or large-scale datacenter operator
Hands-on transfer pricing experience for intercompany services or compute, including benchmarking and documentation
Experience with the owner-operator transition: construction-period capitalization, placed-in-service timing, property tax during buildout, and sales and use tax on construction inputs versus operating equipment
Experience with non-US datacenter tax regimes and cross-border infrastructure structures
JD, LL.M. in Taxation, CPA, or MST a plus
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.