Director, US International Tax Planning
Core
Lead US international tax planning for a rapidly scaling AI company, analyzing consequences of new entities, intercompany arrangements, and cross-border agreements to structure them efficiently.
Role type
Senior IC international tax director (planning & M&A integration)
Builds
Tax-efficient entity structures, integration plans for acquired businesses, and compliant international filing positions
Domain
US International Tax, Mergers & Acquisitions, Multinational Technology
Deliverable
production ML models | product features | dashboards & analysis | research | client delivery | infrastructure | physical/clinical work
Required skills
US international tax provisions (Subpart F, NCTI, BEAT, FTC), Subchapter C entity structuring, tax modeling & scenario analysis, transfer pricing integration, IRS examination support, technical memo writing, outside advisor management
Preferred skills
CPA/JD/LLM in taxation, 10-15 years US international tax experience, post-acquisition integration planning, Pillar Two/FDDEI knowledge, partnership tax structures, large cross-border commercial agreements, data center/infrastructure investments, AI tool usage in tax research
Technologies
US tax code, regulations, administrative guidance, tax modeling software, Claude
Responsibilities
Lead end-to-end US international tax planning projects from analysis to implementation; Analyze tax consequences of new jurisdictions, intercompany arrangements, and cross-border agreements; Perform technical analysis under Subpart F, NCTI, BEAT, and foreign tax credit rules; Apply Subchapter C to entity formations, contributions, and reorganizations; Define assumptions and review models quantifying tax impacts of planning alternatives; Support M&A tax team with post-closing integration step plans; Draft technical memoranda supporting planning positions and ASC 740 treatment; Partner with compliance and transfer pricing for accurate international filings; Scope and manage outside advisors; Track legislative/regulatory developments and assess impact; Support responses to IRS inquiries
Seniority
Senior, hands-on IC with strategic planning scope
