Director, US International Tax Planning

Anthropic Limited; San Francisco (CA); On-site; USD 300,000 - 550,000; Full time

Job summary

Anthropic Limited in San Francisco, CA, seeks an International Tax Director to lead planning, M&A, and policy work as the company expands in the US and internationally. You will own the US international tax provisions, including subpart F, BEAT, and foreign tax credits, and advise on subchapter C interactions with entity structures.

This hands-on, technical role requires writing memos, reviewing models, and driving implementation across Finance & Accounting, Legal, Treasury, and Accounting to

Qualifications

• Experience leading US international tax planning projects.
• Knowledge of subpart F, BEAT, and foreign tax credits.
• Ability to work with cross-functional teams including Legal, Treasury, and Accounting.

Responsibilities

• Lead and support US international tax planning projects from initial analysis through implementation, and contribute to how the planning group identifies and prioritizes its work
• Analyze the US international tax consequences of business initiatives, including new entities and jurisdictions, intercompany arrangements, funding and repatriation, and cross-border commercial and compute agreements, and recommend how to structure them
• Perform and review technical analysis under subpart F, NCTI, BEAT, and the foreign tax credit rules, including expense allocation and apportionment and the interaction among these provisions
• Apply subchapter C to entity formations, contributions, distributions, liquidations, and internal reorganizations, including earnings and profits and stock basis analysis
• Define the assumptions and scenarios for models that quantify the cash tax and effective tax rate impact of planning alternatives, acquired structures, and legislative and regulatory changes; review those models for technical accuracy and provide input on them; and be accountable for the conclusions drawn from them
• Support the M&A tax team after closing by developing the step plans that integrate acquired entities into Anthropic's structure, reviewing the modeling of the

Skills

US international tax

M&A tax

Cross-border tax

Tax policy

Job description

About Anthropic

Anthropic’s mission is to create reliable, interpretable, and steerable AI systems. We want AI to be safe and beneficial for our users and for society as a whole. Our team is a quickly growing group of committed researchers, engineers, policy experts, and business leaders working together to build beneficial AI systems.

About the role

Anthropic's Tax team sits within Finance & Accounting and is responsible for the company's tax position as we grow quickly in the US and internationally. New entities and jurisdictions, intercompany arrangements, financing, acquired businesses, and large commercial and compute agreements all carry US international tax consequences, and those consequences are getting larger and more complex as the company scales. We are looking for an International Tax Director to join our Tax planning, M&A, and Policy team. Your core subject matter is the US international provisions, including subpart F, NCTI, FDDEI, BEAT, and the foreign tax credit, along with the subchapter C rules that govern how we form, fund, and structure entities.

This is a hands-on technical role. You will write the memos behind your recommendations, review the models that support them, and see your projects through to implementation, often in areas where the facts are new to the company or the law has recently changed and guidance is still developing. Our M&A tax colleagues lead diligence and deal structure on transactions, and once a deal closes you will help work out how the acquired business fits into our international structure. You will also work closely with the colleagues who own the tax provision, compliance, and transfer pricing, and with Legal, Treasury, and Accounting. If you enjoy carrying hard technical questions through to implementation as part of a small team, we would like to hear from you.

Key responsibilities

• Lead and support US international tax planning projects from initial analysis through implementation, and contribute to how the planning group identifies and prioritizes its work
• Analyze the US international tax consequences of business initiatives, including new entities and jurisdictions, intercompany arrangements, funding and repatriation, and cross-border commercial and compute agreements, and recommend how to structure them
• Perform and review technical analysis under subpart F, NCTI, BEAT, and the foreign tax credit rules, including expense allocation and apportionment and the interaction among these provisions
• Apply subchapter C to entity formations, contributions, distributions, liquidations, and internal reorganizations, including earnings and profits and stock basis analysis
• Define the assumptions and scenarios for models that quantify the cash tax and effective tax rate impact of planning alternatives, acquired structures, and legislative and regulatory changes; review those models for technical accuracy and provide input on them; and be accountable for the conclusions drawn from them
• Support the M&A tax team after closing by developing the step plans that integrate acquired entities into Anthropic's structure, reviewing the modeling of the