Tax Director, Corporate Tax Planning and M&A

About the TeamOpenAI 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 RoleWe’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, ... (truncated, view full listing at source)