The opportunity
Anthropic is making significant, sustained investment in compute infrastructure to support our AI safety mission. We are looking for a Senior Manager, Infrastructure Tax to work alongside the Infrastructure Tax Lead on that portfolio.
What you'll do
Run deal intake for individual infrastructure transactions: gather facts on site specs, counterparty structure, commercial terms, and timing; prepare the structure review and term-sheet input for the Lead's sign-off early enough to shape the deal
Analyze service versus lease characterization, entity structure, and contract: tax provisions for assigned deals, working with the Tax Transactions and Tax Planning teams and escalating judgment calls to the Infra Tax Lead
Build and maintain the after-tax deal economics models: bonus depreciation on large-scale buildouts, NOL utilization, and scenario analysis; work with Tax Planning, Tax Operations, and Infrastructure Accounting so the tax assumptions in deal approval packages are accurate
Prepare the tax-side inputs for Technical Accounting on lease-versus-purchase: treatment, consolidation questions, capitalization policy, and book-tax differences across deal structures
Execute on datacenter entity structures across jurisdictions under the Lead's: direction: entity formation, operationalization with local teams, contemporaneous documentation, withholding on cross-border financing, permanent establishment analysis, and debt-versus-equity characterization
Support transfer pricing on the infrastructure footprint: gather the facts, maintain the documentation for intercompany compute pricing, and coordinate benchmarking
What they're looking for
- to 10 years of tax experience with exposure to datacenter or infrastructure: tax planning, including some international work
- Big 4 or law firm experience in a datacenter or infrastructure tax practice
- 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
- Experience with the owner-operator transition: construction-period capitalization, placed-in-service timing, property tax during buildout, and sales and use tax on construction inputs versus operating equipment
- Experience with non-US datacenter tax regimes and cross-border infrastructure structures
- JD, LL.M. in Taxation, CPA, or MST a plus
