The opportunity
OpenAI’s Tax and Trade team sits at the center of OpenAI’s global growth, shaping how cutting-edge AI products, partnerships, and infrastructure scale across borders while navigating complex tax, trade, and regulatory regimes. We operate as strategic operators, not just…
What you'll do
Serve as a senior tax business partner across OpenAI, advising on strategic: business decisions, product development, commercial models, infrastructure investments, financing initiatives, and international growth.
Serve as the lead tax advisor on complex commercial, infrastructure, and: financing arrangements. Evaluate tax and economic trade-offs and translate advice into practical structures and contractual positions.
Help shape major commercial and financing arrangements by evaluating: alternative structures, modeling tax and economic outcomes, and advising on the tradeoffs among cost, flexibility, accounting treatment, risk, and speed.
Advise on structured finance and capital markets transactions, including debt: and equity financings, credit facilities, asset-backed arrangements, third-party financing, intercompany funding, and other bespoke financing structures.
Partner closely with commercial and legal teams on complex contracting: matters, including compute and infrastructure agreements, customer arrangements, technology and IP agreements, supply agreements, and strategic partnerships.
Translate tax considerations into practical contracting positions, including: payment characterization, pricing, ownership, withholding, gross-ups, indemnities, tax responsibilities, and information rights.
What they're looking for
- Advise Product and commercial teams as OpenAI develops and scales products,: including product launches, pricing and monetization models, distribution channels, customer offerings, and new revenue streams.
- Partner with business teams to design scalable operating and contracting: models that support growth across products, customer segments, and geographies.
- Support OpenAI’s international expansion by advising on market entry, legal: entity structures, operating models, customer contracting, cross-border service and revenue flows, intercompany arrangements, and the scaling of regional operations.
- Evaluate the broader tax implications of new business activities, including: permanent establishment, withholding, transfer pricing, income characterization, and other cross-border considerations.
