Tax Director (AI)

Location: San Francisco, CA, United States; hybrid work model with 3 days in the office per week. Relocation assistance is available to new employees.

Salary: $347K–$385K base pay annually, plus equity, performance-related bonuses for eligible employees, and benefits.

Company

OpenAI is an AI research and deployment company developing and deploying general-purpose AI systems with a focus on safety and broad human benefit.

What you will do

• Advise on tax aspects of acquisitions, joint ventures, reorganizations, divestitures, post-close integration, and other strategic transactions.
• Provide international tax planning and global operating model advice covering legal entity footprint, intercompany arrangements, IP ownership and use, customer contracting models, and cross-border service flows.
• Support global expansion, new market entry, operating-footprint changes, regional scaling, go-to-market initiatives, strategic partnerships, customer contracting, and new revenue models.
• Evaluate permanent establishment, withholding tax, treaty, source and character, transfer pricing, and other international tax matters.
• Monitor US and international tax law and policy developments, including Pillar Two and other global tax reforms, and assess their business implications.
• Advise on financing and treasury initiatives, manage external advisors, coordinate stakeholders, and build scalable tax advisory frameworks and playbooks.

Requirements

• J.D. and strong academic credentials.
• 12+ years of progressive international tax experience, ideally combining law-firm and in-house experience at a high-growth multinational business.
• Strong experience with 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, intercompany arrangements, IP planning, and global operating model design.
• Experience with Pillar Two and global tax policy developments, with the ability to translate legislative change into practical business advice.
• Ability to turn complex tax concepts into clear, actionable recommendations for non-tax stakeholders and executive leadership.
• Exceptional judgment, presence, and communication skills; comfort operating at senior organizational levels and building credibility across Legal, Finance, Product, Infrastructure, Corporate Development, and commercial teams.

Nice to have

• LL.M. in Taxation.
• A mix of law-firm and in-house experience at a high-growth multinational business.

Culture & Benefits

• Hybrid work with three office days per week and relocation assistance for eligible employees.
• Medical, dental, and vision insurance, with employer contributions to Health Savings Accounts.
• 401(k) plan with employer match, flexible or up to 15 days of paid time off depending on exemption status, paid holidays, office closures, sick or safe time, and parental, medical, and caregiver leave.
• Mental health and wellness support, employer-paid basic life and disability coverage, and an annual learning and development stipend.
• Daily office meals, eligible meal delivery credits, commuter benefits, charitable donation matching, and wellness stipends may be provided.

Hiring process

• Additional benefits details are provided during the hiring process.
• Background checks are administered in accordance with applicable law.