Tax Director, Tax Counsel

OpenAI•San Francisco, CA

10d•$347,000 - $385,000•Hybrid

About The Position

OpenAI is hiring a Tax Director to advise on the company’s global tax strategy and support its continued international expansion. The role partners 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. The Tax Director brings international tax expertise and practical business judgment to help OpenAI manage risk while moving quickly across a rapidly evolving global footprint. The role translates complex tax rules into clear recommendations, builds scalable frameworks, and serves as a trusted advisor to senior stakeholders. The position is based in San Francisco, California, under a hybrid work model requiring three days in the office per week. Relocation assistance is offered to new employees.

Requirements

J.D. and strong academic credentials.
12+ years of progressive international tax experience.
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.
Ability to distill complex tax concepts into clear, actionable recommendations for non-tax stakeholders and executive leadership.
Exceptional judgment, presence, and communication skills, with comfort operating at senior levels of an organization.
Track record of building trust and credibility across Legal, Finance, Product, Infrastructure, Corporate Development, and commercial teams.

Nice To Haves

LL.M. in Taxation.
Experience combining law firm and in-house work at a high-growth multinational business.

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 business planning and operating models.
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, 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 balancing tax efficiency, risk management, operational feasibility, and business priorities.