Tax Director, Tax Counsel

About the Role

We’re hiring a Tax Director to advise on OpenAI’s global tax strategy and support the company’s continued international expansion. This role will partner closely with Legal, Finance, Corporate Development, and commercial teams on cross-border tax planning, operating model design, market entry, strategic partnerships, product launches, intercompany arrangements, and complex commercial transactions.

Responsibilities

• 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.
• 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.

Qualifications

• A J.D. and strong academic credentials; LL.M. in Taxation a plus.
• 12+ years of progressive international tax experience, ideally with a mix of law firm and in-house experience at a high-growth multinational business.
• Strong foundation in complex domestic and cross-border M&A, joint ventures, reorganizations, and post-acquisition integrations.
• Extensive experience advising on cross-border commercial arrangements, market entry, strategic partnerships, and international expansion.
• Deep technical expertise in US international tax, including GILTI, FDII, BEAT, foreign tax credits, withholding tax, tax treaties, source and character of income, Subpart F, and permanent establishment principles.
• Strong understanding of transfer pricing principles, intercompany arrangements, IP planning, and global operating model design.
• Experience with Pillar Two and global tax policy developments, and ability to translate legislative change into practical business advice.
• Proven ability to distill complex tax concepts into clear, actionable recommendations for non-tax stakeholders and executive leadership.
• Exceptional judgment, presence, and communication skills; comfortable operating at senior levels of the organization.
• Track record of building trust and credibility across Legal, Finance, Product, Infrastructure, Corporate Development, and commercial teams.

Workplace & Location

This role is based in San Francisco, CA. We use a hybrid work model of 3 days in the office per week and offer relocation assistance to new employees.