M&A Tax Director

About the company

The company’s mission is to create reliable, interpretable, and steerable AI systems. We want AI to be safe and beneficial for our users and for society as a whole. Our team is a quickly growing group of committed researchers, engineers, policy experts, and business leaders working together to build beneficial AI systems.

About the role

We are looking for an M&A Tax Director to join our Tax Team at the company. As the company pursues an active and growing pipeline of acquisitions, acqui-hires, data center investments, joint ventures and other strategic transactions, this role will be a core member of our transactions tax function, working closely with our M&A Tax Lead. You will support and lead tax workstreams across the deal lifecycle, from initial evaluation through post-closing integration, and serve as a trusted resource for our Corporate Development, Legal, and Finance teams. Beyond transactions, this role will support a wide range of strategic and operational tax matters. This is a high-impact role with significant ownership and a front-row seat to some of the most consequential transactions and tax planning work happening in AI today. If you're excited to help build a function from the ground up at a company working on one of the most important challenges of our time, we'd love to hear from you.

Key responsibilities

• Lead and manage tax workstreams for acquisitions, mergers, acqui-hires, asset and stock purchases, corporate reorganizations, financing transactions, and minority investments, including tax due diligence, risk identification and quantification, and deal structuring analysis

• Partner with Corporate Development on deal pipeline evaluation, providing early-stage tax input to inform go/no-go decisions and deal economics

• Draft and review tax provisions in transaction documents, including purchase agreements, merger agreements, and ancillary deal documents

• Support post-acquisition tax integration planning, including entity rationalization, intercompany restructuring, and tax attribute analysis

• Advise on tax considerations for data center investments, build-to-suit arrangements, leases, and related infrastructure transactions, and coordinate with relevant team members on incentives, credits, and indirect tax matters

• Advise on the tax structuring of joint ventures, strategic partnerships, and REIT-related investment structures, including real estate and data center joint venture arrangements

• Help build and maintain transactions tax playbooks, due diligence checklists, and internal processes

• Coordinate with the tax compliance and provision teams to ensure clean handoff of closed transactions, including documentation of structure, elections, tax attributes, and reporting positions

• Prepare technical tax memoranda documenting transactions, material tax positions, and risk assessments to support internal sign-off, financial statement audit, and tax return filing positions

Minimum qualifications

• JD or CPA

• M&A and transactional tax experience gained at a large law firm, Big 4 M&A tax practice, or in-house transactions tax team

• Strong technical expertise in federal and state tax rules governing corporate transactions, including Section 338, Section 368 reorganizations, and asset and stock acquisitions

• Experience running tax due diligence workstreams and quantifying tax exposures in transaction contexts

• Experience drafting and negotiating tax provisions in M&A transaction documents

• Experience supporting post-acquisition integration from a tax perspective, including entity rationalization and intercompany restructuring

Preferred qualifications

• 7-10 years of tax experience, with significant M&A and transactional tax exposure

• LL.M. in Taxation or MST

• Experience providing general tax advisory support, including advising on commercial contracts, operational matters, and cross-functional tax questions

• Experience with joint ventures, partnerships, minority investments, revenue-sharing arrangements and financing transactions

• Experience with REITs, including REIT qualification and tax considerations for REIT joint ventures and real estate investment structures

• Experience with data center acquisitions, infrastructure transactions, or real estate tax considerations

• Tax experience at a high-growth technology company

• Knowledge of state and local tax (SALT) implications of transactions

• Experience with equity compensation tax issues in the context of acquisitions and acqui-hires

• Exposure to international tax aspects of cross-border acquisitions

• Exceptional communication skills, with the ability to translate complex tax issues into clear, actionable guidance for Legal, Finance, and Corporate Development partners

• Comfort with ambiguity and a willingness to help build processes from scratch in fast-paced environments

• Passion for the company's mission to build safe, transformative AI systems

The annual compensation range for this role is listed below.

For sales roles, the range provided is the role’s On Target Earnings ("OTE") range, meaning that the range includes both the sales commissions/sales bonuses target and annual base salary for the role.

Annual Salary

$230,000 — $300,000 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.

For roles performing work in California: We will consider for employment all qualified applicants, including those with arrest or conviction records or criminal histories, in a manner consistent with the requirements of applicable state and local laws, including the San Francisco Fair Chance Ordinance, the City of Los Angeles’ Fair Chance Initiative for Hiring Ordinance, the Los Angeles County Fair Chance Ordinance for Employers, and the California Fair Chance Act.

We encourage you to apply even if you do not believe you meet every single qualification. Not all strong candidates will meet every single qualification as listed.  Research shows that people who identify as being from underrepresented groups are more prone to experiencing imposter syndrome and doubting the strength of their candidacy, so we urge you not to exclude yourself prematurely and to submit an application if you're interested in this work. We think AI systems like the ones we're building have enormous social and ethical implications. We think this makes representation even more important, and we strive to include a range of diverse perspectives on our team.

Your safety matters to us. To protect yourself from potential scams, remember that the company recruiters only contact you from @the company.com email addresses. In some cases, we may partner with vetted recruiting agencies who will identify themselves as working on behalf of the company. Be cautious of emails from other domains. Legitimate the company recruiters will never ask for money, fees, or banking information before your first day. If you're ever unsure about a communication, don't click any links—visit  the company.com/careers  directly for confirmed position openings.

How we're different

We believe that the highest-impact AI research will be big science. At the company 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 the company, 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!

The company 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. Guidance on Candidates' AI Usage:  Learn about  our policy for using AI in our application process.