About the Team
OpenAI’s Tax and Trade team sits at the center of OpenAI’s global growth, shaping how cutting-edge AI products, partnerships, and infrastructure scale across borders while navigating complex tax, trade, and regulatory regimes. We operate as strategic operators, not just compliance experts, embedding early in product, finance, policy, and infrastructure decisions to manage risk, unlock incentives, and enable OpenAI to grow responsibly and competitively worldwide.
About the Role
We’re hiring a Tax Director to help shape some of OpenAI’s most important business, product, infrastructure, and financing initiatives. This role will sit at the intersection of tax, finance, technology, and commercial strategy, advising on the investments, products, partnerships, and operating decisions that enable OpenAI to scale.
You will serve as a senior tax business partner to Finance, Legal, Infrastructure, Treasury, Accounting, Product, and commercial teams. Your work will span compute and infrastructure investments, structured financings, commercial contracting, product strategy, new business models, and international expansion.
This is a broad, highly commercial role for someone who enjoys solving new problems and influencing business decisions. The ideal candidate combines strong tax judgment with financial acumen, intellectual curiosity, and an understanding of transaction economics, contractual risk allocation, and business operations. You will engage early in strategic initiatives, help teams evaluate possibilities, and develop practical structures that support OpenAI’s growth.
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.
In this role, you will:
Serve as a senior tax business partner across OpenAI, advising on strategic business decisions, product development, commercial models, infrastructure investments, financing initiatives, and international growth.
Serve as the lead tax advisor on complex commercial, infrastructure, and financing arrangements. Evaluate tax and economic trade-offs and translate advice into practical structures and contractual positions.
Help shape major commercial and financing arrangements by evaluating alternative structures, modeling tax and economic outcomes, and advising on the tradeoffs among cost, flexibility, accounting treatment, risk, and speed.
Advise on structured finance and capital markets transactions, including debt and equity financings, credit facilities, asset-backed arrangements, third-party financing, intercompany funding, and other bespoke financing structures.
Partner closely with commercial and legal teams on complex contracting matters, including compute and infrastructure agreements, customer arrangements, technology and IP agreements, supply agreements, and strategic partnerships.
Translate tax considerations into practical contracting positions, including payment characterization, pricing, ownership, withholding, gross-ups, indemnities, tax responsibilities, and information rights.
Advise Product and commercial teams as OpenAI develops and scales products, including product launches, pricing and monetization models, distribution channels, customer offerings, and new revenue streams.
Partner with business teams to design scalable operating and contracting models that support growth across products, customer segments, and geographies.
Support OpenAI’s international expansion by advising on market entry, legal entity structures, operating models, customer contracting, cross-border service and revenue flows, intercompany arrangements, and the scaling of regional operations.
Evaluate the broader tax implications of new business activities, including permanent establishment, withholding, transfer pricing, income characterization, and other cross-border considerations.
Monitor relevant tax law, regulatory, and financial market developments and assess their implications for OpenAI’s products, transactions, financing strategy, and operating model.
Build contracting guidelines, product advisory frameworks, standard tax positions, decision tools, and escalation protocols that allow recurring business activities to scale quickly and consistently.
Manage external advisors and coordinate across internal tax specialties to deliver timely, integrated, and practical advice.
Communicate complex tax and business issues clearly to senior leaders and non-tax stakeholders, focusing on the business implications, available choices, and recommended paths forward.
You might thrive in this role if you:
A J.D. with 12+ years of progressive tax experience, ideally with experience across a law firm, accounting firm, financial institution, or high-growth multinational business. An LL.M. in Taxation is a plus.
Broad tax expertise and a demonstrated ability to advise across commercial, product, financing, and international business matters.
Significant experience with structured finance, capital markets, corporate finance, or other complex financing transactions.
Strong understanding of tax considerations arising from debt and equity instruments, credit arrangements, leases, asset financings, derivatives, hedging, and other financial products.
Meaningful experience reviewing and negotiating complex commercial agreements and converting technical tax issues into workable contractual solutions.
Experience advising product and business teams on new offerings, pricing and revenue models, customer arrangements, and the scaling of commercial activities.
Experience supporting international expansion, market entry, cross-border operating models, and global commercial arrangements.
Experience advising on large-scale infrastructure, energy, technology, or other capital-intensive arrangements. Experience with compute, data centers, digital infrastructure, or long-term capacity agreements is a plus.
Strong financial and commercial acumen, including the ability to understand transaction economics, financial models, accounting implications, and contractual risk allocation.
Experience using AI tools to enhance tax research, transaction analysis, knowledge management, and business advisory, with an interest in developing AI-enabled workflows that improve the speed, quality, and scalability of the tax function.
Intellectual curiosity and comfort operating in areas without established precedent, with the ability to develop a practical path forward through ambiguity.
Proven ability to distill complex tax, financial, and commercial issues into clear recommendations for business teams and executive leadership.
Exceptional judgment, presence, and communication skills, with the ability to influence decisions and operate credibly at senior levels of the organization.
A track record of building trust and working effectively across Finance, Legal, Infrastructure, Treasury, Accounting, Product, and commercial teams.
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.
Background checks for applicants will be administered in accordance with applicable law, and qualified applicants with arrest or conviction records will be considered for employment consistent with those laws, including the San Francisco Fair Chance Ordinance, the Los Angeles County Fair Chance Ordinance for Employers, and the California Fair Chance Act, for US-based candidates. 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.
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