Senior Manager, Infrastructure Tax

Anthropic•San Francisco, CA

12d•Hybrid

About The Position

Anthropic is making significant, sustained investment in compute infrastructure to support our AI safety mission. We are looking for a Director/Senior Manager, Infrastructure Tax to work alongside the Infrastructure Tax Lead on that portfolio. The Lead owns the integrated tax position across the portfolio. This role carries the day-to-day execution of it: running intake on individual deals, owning defined workstreams end to end, building the models and documentation, and coordinating the work across Legal, Technical Accounting, FP&A, International Tax, Transfer Pricing, and Provision. This is a hands-on role for a tax practitioner who wants to own workstreams on one of Anthropic's largest capital commitments. It reports to the Infrastructure Tax Lead.

Requirements

JD or CPA required; LL.M. in Taxation or MST a plus
Experience supporting entity structures across multiple jurisdictions, including contemporaneous documentation and working with local finance, legal, and accounting teams
Working knowledge of cross-border withholding on intercompany and third-party financing, permanent establishment analysis, and debt-versus-equity characterization
A track record of owning discrete workstreams on capital-intensive deals from intake through post-close and carrying them to completion with limited supervision
The ability to work across Legal, Accounting, FP&A, and business teams, carry several deals in parallel, and know when to escalate
Strong written and verbal communication, including written analysis that a tax lead can review and sign off on quickly
Comfort with ambiguity and a fast-moving environment
Bachelor’s degree or an equivalent combination of education, training, and/or experience
A field relevant to the role as demonstrated through coursework, training, or professional experience

Nice To Haves

8 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

Responsibilities

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
Prepare the quarterly inputs for the tax provision team on new structures and deferred tax positions so there are no surprises between deal close and quarter close
Draft and maintain infrastructure tax playbooks, issue-spotting checklists, and internal trackers, and keep them current as deals close