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Tax Director, Business Advisory and Strategic Finance

OpenAI - San Francisco, CA, United States - Hybrid - posted 2026-08-19

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OpenAI's Tax and Trade team is seeking a Tax Director to serve as a senior strategic business partner across the organization. This role sits at the intersection of tax, finance, technology, and commercial strategy, advising on investments, products, partnerships, and operating decisions that enable OpenAI to scale globally. You will partner with Finance, Legal, Infrastructure, Treasury, Accounting, Product, and commercial teams on a broad range of initiatives including compute and infrastructure investments, structured financings, commercial contracting, product strategy, new business models, and international expansion. This is a highly commercial role requiring strong tax judgment combined with financial acumen and business operations understanding. Key responsibilities include: serving as lead tax advisor on complex commercial, infrastructure, and financing arrangements; evaluating tax and economic trade-offs to develop practical structures; advising on structured finance and capital markets transactions including debt/equity financings, credit facilities, and asset-backed arrangements; partnering with commercial and legal teams on complex contracting matters; translating tax considerations into practical contracting positions; advising Product teams on pricing, monetization, distribution, and revenue models; supporting international expansion through market entry strategy, entity structuring, and cross-border arrangements; evaluating permanent establishment, withholding, transfer pricing, and income characterization implications; building scalable contracting guidelines and advisory frameworks; managing external advisors; and communicating complex issues clearly to senior leaders. Ideal candidates bring a J.D. with 12+ years of progressive tax experience across law firms, accounting firms, financial institutions, or high-growth multinationals (LL.M. in Taxation a plus). Required expertise spans commercial, product, financing, and international tax matters, with significant experience in structured finance, capital markets, and corporate finance transactions. Strong understanding of tax considerations for debt/equity instruments, credit arrangements, leases, asset financings, derivatives, and financial products is essential. Experience reviewing and negotiating complex commercial agreements, advising on new product offerings and revenue models, supporting international expansion, and advising on large-scale infrastructure or capital-intensive arrangements (especially compute, data centers, or long-term capacity agreements) is highly valued. The role is based in San Francisco with a hybrid work model of 3 days in-office per week. Relocation assistance is offered.

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