Overview
A leading AI-focused organization is seeking an Infrastructure Tax Lead to manage tax responsibilities across its compute infrastructure investments supporting AI safety initiatives. This role involves close collaboration with the Infrastructure team and coordination with Legal, Technical Accounting, FP&A, International Tax, Transfer Pricing, Provision, and Incentives teams.
Responsibilities
- Act as the embedded tax partner for the Infrastructure team during deal intake by gathering details on site specifications, counterparty structures, commercial terms, and timing; provide early structure review and term-sheet input to influence deal terms.
- Lead the incentives workstream covering state and local incentives, sales and use tax exemptions, and site selection tax input; ensure incentive commitments and compliance obligations are integrated into the tax position for each site.
- Collaborate with Tax Transactions and Tax Planning teams on lease characterization, entity structure, and contract tax provisions; own tax analysis on lease-versus-purchase decisions and treatment of non-standard structures.
- Lead after-tax deal economics including bonus depreciation modeling for large-scale buildouts, net operating loss utilization, and scenario analysis; partner with Tax Planning and FP&A to ensure accurate tax assumptions in deal approval packages.
- Coordinate with Technical Accounting on lease-versus-purchase treatment, consolidation issues, capitalization policy, and book-tax differences across various deal structures.
- Establish and maintain datacenter entity structures across jurisdictions, including 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 policies for the infrastructure footprint, including intercompany compute pricing, benchmarking, and documentation to support scaling intercompany flows.
- Work with the tax provision team on quarterly impacts of new structures and deferred tax positions to avoid surprises between deal close and quarter close.
- Develop and maintain infrastructure tax playbooks, issue-spotting checklists, and internal processes to scale the tax function efficiently with deal volume.
Requirements
- Minimum 12 years of tax experience with significant exposure to datacenter, REIT, or large-scale real estate tax planning, including substantial international experience.
- JD or CPA required; LL.M. in Taxation or MST is a plus.
- Deep technical expertise in lease characterization and Section 467, as well as bonus depreciation modeling for capital-intensive buildouts.
- Experience establishing and maintaining entity structures across multiple jurisdictions, including contemporaneous documentation and collaboration with local finance, legal, and accounting teams.
- Proficiency in cross-border withholding on intercompany and third-party financing, permanent establishment analysis, and debt-versus-equity characterization.
- Proven track record of managing integrated tax positions across a portfolio of deals, overseeing the process from term sheet through post-close.
- Strong cross-functional coordination skills, comfortable leading efforts across Legal, Accounting, FP&A, and business teams without formal authority.
- Exceptional written and verbal communication skills, capable of translating complex tax positions into clear guidance for leadership and deal teams.
- Ability to work effectively in ambiguous, fast-moving environments and build processes from scratch.
Preferred Qualifications
- Experience at a Big 4 firm or law firm specializing in datacenter, REIT, or infrastructure tax.
- 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.
- Familiarity with owner-operator transitions, including construction-period capitalization, placed-in-service timing disputes, property tax during buildout, and sales/use tax on construction inputs versus operating equipment.
- Background in state and local incentives, economic development negotiation, or site selection tax.
- Experience with non-US datacenter tax regimes and cross-border infrastructure structures.
- Existing relationships with datacenter developers, REIT tax counsel, or Big 4 infrastructure tax teams.
Compensation & Benefits
- Annual salary range: $300,000 to $370,000 USD.
- Competitive compensation and benefits package.
- Flexible working hours with a hybrid policy requiring approximately 25% office presence.
- Visa sponsorship available with support from immigration counsel.
Location
- The role is based in an office environment with a hybrid work policy.
Additional Information
- Candidates are encouraged to apply even if they do not meet every qualification listed.
- The organization values diverse perspectives and strives for inclusive representation.
- Applicants should be cautious of recruitment scams; official recruiters use company-specific email domains and do not request money or banking information before employment.