The opportunity
Anthropic's Tax team sits within Finance & Accounting and is responsible for the company's tax position as we grow quickly in the US and internationally. New entities and jurisdictions, intercompany arrangements, financing, acquired businesses, and large commercial and compute…
What you'll do
Lead and support US international tax planning projects from initial analysis: through implementation, and contribute to how the planning group identifies and prioritizes its work
Analyze the US international tax consequences of business initiatives,: including new entities and jurisdictions, intercompany arrangements, funding and repatriation, and cross-border commercial and compute agreements, and recommend how to structure them
Perform and review technical analysis under subpart F, NCTI, BEAT, and the: foreign tax credit rules, including expense allocation and apportionment and the interaction among these provisions
Apply subchapter C to entity formations, contributions, distributions,: liquidations, and internal reorganizations, including earnings and profits and stock basis analysis
Define the assumptions and scenarios for models that quantify the cash tax: and effective tax rate impact of planning alternatives, acquired structures, and legislative and regulatory changes; review those models for technical accuracy and provide input on them; and be accountable for the conclusions drawn from them
Support the M&A tax team after closing by developing the step plans that: integrate acquired entities into Anthropic's structure, reviewing the modeling of the alternatives, and leading follow-on planning for the combined structure
What they're looking for
- CPA, JD, or LLM in taxation
- years of extensive US international tax experience, for example a combination: of public accounting or law firm practice and an in-house role at a multinational technology company
- Experience with post-acquisition integration planning, including step plans: and modeling for bringing acquired entities into an existing international structure
- Direct experience with transfer pricing, Pillar Two, or the FDDEI deduction: and how they interact with the US international provisions
- Familiarity with the tax rules of the non-US jurisdictions where a US technology company typically operates
- Have working knowledge of partnership tax as it applies to multinational: groups, including the formation and funding of joint ventures, allocations and distributions, and how partnership structures interact with the US international provisions
- Experience planning around large cross-border commercial arrangements, such: as cloud, compute, or licensing agreements, or standing up entities in new jurisdictions
- Experience with infrastructure or capital-intensive investments, such as data: centers, energy, or similar assets, including joint venture and financing structures
