Tax Director, Corporate Tax Planning and M&A

About the Team

OpenAI Finance is responsible for ensuring the organization is set up for success in pursuit of its mission.

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 support the structuring and execution of complex domestic and cross-border M&A and strategic transactions, including joint ventures, acquisitions, divestitures, and reorganizations. This role is roughly split between transaction support and broader business advisory, partnering closely with Legal, Finance, Corporate Development, and commercial teams on international tax matters tied to product launches, global expansion, and key commercial and intercompany arrangements. You will bring deep technical expertise and provide practical, tax-efficient guidance that helps OpenAI scale globally, move quickly, and manage risk across a rapidly evolving business.

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:

• Support the tax structuring and execution of complex domestic and cross-border M&A and strategic transactions, including joint ventures, acquisitions, divestitures, and reorganizations, partnering with Corporate Development and Legal throughout the deal lifecycle.

• Conduct and coordinate tax due diligence for potential acquisitions and investments, surfacing key risks, deal sensitivities, and opportunities, and translating findings into practical deal recommendations.

• Review, draft, and negotiate tax-related provisions in transaction documents to align with business objectives and manage tax risk.

• Collaborate with Legal, Finance, and deal teams to evaluate alternative structures and deliver clear, actionable tax input on transaction design, approvals, and execution.

• Drive post-close tax integration workstreams including entity rationalization and alignment to OpenAI's operating model, in coordination with cross-functional stakeholders.

• Serve as a core tax business partner on international tax planning and day-to-day advisory, including guidance on global expansion initiatives, new market entry, and changes in operating footprint.

• Advise product and commercial teams on tax considerations for product launches, go-to-market motions, customer contracting, partner arrangements, and other revenue models, with a focus on scalability and risk management.

• Support tax aspects of financing and treasury initiatives, including intercompany funding, capital structure planning, and third-party financings.

• Monitor tax law and policy developments, US and international, and assess implications for business planning, transactions, and commercial strategy, recommending pragmatic risk mitigation steps.

• Manage external advisors and coordinate across internal stakeholders to ensure timely, high-quality tax support across both transactions and ongoing business initiatives.

• Build scalable frameworks, playbooks, and processes that enable consistent, repeatable tax advisory for a fast-growing global business, including tooling, guidance materials, and stakeholder enablement.

You might thrive in this role if you have:

• A 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.

• Fluency in fundamental US international tax rules including, NCTI, FDDEI, BEAT, foreign tax credits, withholding tax, source and character of income.

• 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.

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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Compensation Range: $347K - $385K