Tax Director, Tax Counsel

OpenAI

. Support tax aspects of strategic transactions, including acquisitions, joint ventures, reorganizations, divestitures, and post-close integration .

Posted 10/27/2026full-timeSan Francisco • California • United StatesLead💰 $347,000 - $385,000 per yearWebsite

Core Competencies

Role fit

Core Competencies

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Demonstrates extensive expertise in international tax planning, including cross-border transactions, transfer pricing, and compliance with US and global tax laws. Proven ability to provide strategic tax advice to senior leadership and cross-functional teams, ensuring alignment with business objectives.

Highest-signal resume keywords

International Tax ExperienceCross-Border M&ATransfer Pricing PrinciplesTax Treaty KnowledgePillar Two Compliance

ATS Keywords

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Applicant Tracking System Keywords

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Hard Skills

International Tax PlanningCross-Border TransactionsTax ComplianceM&A AdvisoryIntercompany ArrangementsIP PlanningTax TreatiesWithholding TaxPermanent EstablishmentGILTI

Soft Skills

Exceptional JudgmentCommunication SkillsBuilding TrustCredibilityStakeholder Management

Certifications & Qualifications

J.D.LL.M. in Taxation

Industry Keywords

Global Tax ReformStrategic PartnershipsMarket EntryCorporate DevelopmentHigh-Growth Multinational

About the role

Key responsibilities & impact

Support tax aspects of strategic transactions, including acquisitions, joint ventures, reorganizations, divestitures, and post-close integration
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
Monitor US and international tax law and policy developments, including Pillar Two and other global tax reform initiatives
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
Build scalable frameworks, playbooks, and processes for consistent, repeatable tax advisory
Communicate complex tax issues clearly to non-tax stakeholders and senior leadership, helping drive balanced business decisions

Requirements

What you’ll need

A J.D. and strong academic credentials; LL.M. in Taxation a plus
12+ years of progressive international tax experience
Ideally, 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
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
Track record of building trust and credibility across Legal, Finance, Product, Infrastructure, Corporate Development, and commercial teams

Benefits

Comp & perks

Equity
Performance-related bonus(es) for eligible employees
Medical, dental, and vision insurance for you and your family, with employer contributions to Health Savings Accounts
Pre-tax accounts for Health FSA, Dependent Care FSA, and commuter expenses (parking and transit)
401(k) retirement plan with employer match
Paid parental leave (up to 24 weeks for birth parents and 20 weeks for non-birthing parents)
Paid medical and caregiver leave (up to 8 weeks)
Flexible PTO for exempt employees and up to 15 days annually for non-exempt employees
13+ paid company holidays
Multiple paid coordinated company office closures throughout the year
Paid sick or safe time
Mental health and wellness support
Employer-paid basic life and disability coverage
Annual learning and development stipend
Daily meals in offices and meal delivery credits as eligible
Relocation support for eligible employees
Charitable donation matching and wellness stipends may also be provided