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
Support tax aspects of strategic transactions, including acquisitions, joint: ventures, reorganizations, divestitures, and post-close integration, in partnership with Corporate Development, Legal, and Finance.
Advise on international tax planning and global operating model design,: including legal entity footprint, intercompany arrangements, IP ownership and use, customer contracting models, and cross-border service flows.
Serve as a core tax business partner for global expansion initiatives,: including new market entry, changes in operating footprint, and regional business scaling.
Advise Product, Legal, Finance, and commercial teams on tax considerations: for go-to-market motions, strategic partnerships, customer contracting, and new revenue models.
Evaluate permanent establishment, withholding tax, treaty, source and: character, transfer pricing, and other international tax considerations arising from global business activity.
Monitor US and international tax law and policy developments, including: Pillar Two and other global tax reform initiatives, and assess implications for OpenAI’s business planning and operating model.
What they're looking for
- Advise on tax aspects of financing and treasury initiatives, including: intercompany funding, capital structure planning, and third-party financings.
- Manage external advisors and coordinate internal stakeholders to deliver: timely, practical, and high-quality tax advice across business initiatives.
- Build scalable frameworks, playbooks, and processes that enable consistent,: repeatable tax advisory for a fast-growing global business.
- Communicate complex tax issues clearly to non-tax stakeholders, including: senior leadership, and help drive decisions that balance tax efficiency, risk management, operational feasibility, and business priorities.