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m&a subchapter_c llcs_and_joint_venturesπ Description
- Support structuring and execution of complex M&A and strategic transactions with Legal.
- Lead tax due diligence for acquisitions; surface risks and opportunities.
- Draft and negotiate tax provisions in transaction documents; align with business objectives.
- Collaborate with Legal, Finance, and deal teams on alternative structures and tax input.
- Drive post-close tax integration and entity rationalization.
- Advise product and commercial teams on tax considerations for launches and revenue models.
π― Requirements
- J.D. required; LL.M. in Taxation a plus.
- 12+ years of progressive tax experience in domestic and cross-border M&A.
- Deep expertise in Subchapter C, partnership taxation, flow-through entities; LLCs and joint ventures.
- Fluency in US international tax rules: BEAT, NCTI/FDDEI, foreign tax credits.
- Proven success negotiating high-stakes deals from structuring to integration.
- Experience advising on tax for financing transactions and capital structures in multinational contexts.
- Translate complex tax concepts for non-tax stakeholders, including executive leadership.
π Benefits
- Hybrid work model: 3 days in the office weekly.
- Relocation assistance for new employees.
- Opportunity to shape global tax strategy at OpenAI.
π Relocation support
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