Infrastructure Tax Lead

About the role

Serve as the embedded tax partner to Infrastructure team on deal intake: gather facts on site specs, counterparty structure, commercial terms, and timing; provide structure review and term-sheet input early enough to shape the deal
Lead Incentives workstream on state and local incentives, sales and use exemptions, property tax incentives, and site selection tax input; ensure incentive commitments and compliance obligations are reflected in the integrated tax position for each site
Partner with Tax Transactions and Tax Planning teams on service vs lease characterization, entity structure, and own contract tax provisions; and treatment across a portfolio of non-standard structures
Lead after-tax deal economics: bonus depreciation modeling on large-scale buildouts, NOL utilization, and scenario analysis; partner with Tax Planning, Tax Operations, and Infrastructure Accounting to ensure tax assumptions are reflected accurately in deal approval packages
Coordinate with Technical Accounting on lease-versus-purchase treatment, consolidation questions, capitalization policy, and book-tax differences across a range of deal structures
Stand up and maintain datacenter entity structures across jurisdictions: entity formation, operationalization with local teams, contemporaneous documentation, withholding on cross-border financing, permanent establishment risk, and debt-versus-equity characterization
Partner with transfer pricing on policy for the infrastructure footprint: intercompany compute pricing, benchmarking, and documentation that will withstand scrutiny as intercompany flows scale
Partner with the tax provision team on quarterly impact of new structures and deferred tax positions; ensure there are no surprises between deal close and quarter close
Build and maintain infrastructure tax playbooks, issue-spotting checklists, and internal processes so the function scales with deal volume rather than linearly with headcount

Responsibilities

• Serve as the embedded tax partner to Infrastructure team on deal intake: gather facts on site specs, counterparty structure, commercial terms, and timing; provide structure review and term-sheet input early enough to shape the deal
• Lead Incentives workstream on state and local incentives, sales and use exemptions, property tax incentives, and site selection tax input; ensure incentive commitments and compliance obligations are reflected in the integrated tax position for each site
• Partner with Tax Transactions and Tax Planning teams on service vs lease characterization, entity structure, and own contract tax provisions; and treatment across a portfolio of non-standard structures
• Lead after-tax deal economics: bonus depreciation modeling on large-scale buildouts, NOL utilization, and scenario analysis; partner with Tax Planning, Tax Operations, and Infrastructure Accounting to ensure tax assumptions are reflected accurately in deal approval packages
• Coordinate with Technical Accounting on lease-versus-purchase treatment, consolidation questions, capitalization policy, and book-tax differences across a range of deal structures
• Stand up and maintain datacenter entity structures across jurisdictions: entity formation, operationalization with local teams, contemporaneous documentation, withholding on cross-border financing, permanent establishment risk, and debt-versus-equity characterization
• Partner with transfer pricing on policy for the infrastructure footprint: intercompany compute pricing, benchmarking, and documentation that will withstand scrutiny as intercompany flows scale
• Partner with the tax provision team on quarterly impact of new structures and deferred tax positions; ensure there are no surprises between deal close and quarter close
• Build and maintain infrastructure tax playbooks, issue-spotting checklists, and internal processes so the function scales with deal volume rather than linearly with headcount

You may be a good fit if you have

• 12+ years of tax experience with significant exposure to datacenter, tax planning, including meaningful international range
• JD or CPA required; LL.M. in Taxation or MST a plus
• Experience standing up and maintaining entity structures across multiple jurisdictions, including contemporaneous documentation and operationalizing with local finance, legal, and accounting teams
• Working fluency in cross-border withholding on intercompany and third-party financing, permanent establishment analysis, and debt-versus-equity characterization
• Track record of owning the integrated tax position across a portfolio of deals — not advising on one issue at a time, but carrying the thread across functions from term sheet to post-close
• Demonstrated ability to operate as a cross-functional coordinator: comfortable running point across Legal, Accounting, FP&A, and business teams without formal authority over any of them
• Exceptional written and verbal communication — able to translate complex tax positions into clear guidance for Infrastructure leadership and deal teams
• Comfort with ambiguity and a track record of building processes from scratch in a fast-moving environment

Strong candidates may also have

• 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 disputes, property tax during buildout, and sales/use on construction inputs versus operating equipment
• Background in state and local incentives, economic development negotiation, or site selection tax — either as a dedicated practitioner or as a frequent collaborator
• Experience with non-US datacenter tax regimes and cross-border infrastructure structures
• Existing relationships with datacenter developers, T tax counsel, or Big 4 infrastructure tax teams

The annual compensation range for this role is listed below.

Annual Salary: $300,000 - $385,000 USD

Logistics

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.

How we're different

We believe that the highest-impact AI research will be big science. At Anthropic 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 Anthropic, including: GPT-3, Circuit-Based Interpretability, Multimodal Neurons, Scaling Laws, AI & Compute, Concrete Problems in AI Safety, and Learning from Human Preferences.

Come work with us!

Anthropic 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.

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