M&A Tax Director

About the role

You will own the end-to-end tax strategy for a portfolio of strategic transactions including acquisitions, mergers, acqui-hires, data center investments, joint ventures, and minority investments. You will serve as the primary tax advisor to Corporate Development, providing independent analysis and decision support at every stage of the deal lifecycle. You will design and execute tax due diligence, model multiple tax outcomes, and quantify risks to protect the company's economic interests. You will translate complex federal and state tax rules into practical deal positions and integrate them into negotiation strategies. You will build and refine the core frameworks, playbooks, and controls that define how the company approaches transactions tax. You will act as a trusted partner to Legal and Finance, aligning tax planning with commercial objectives and regulatory constraints. You will own the documentation of technical positions and ensure clear handoffs to compliance and audit functions. This role offers a front-row seat to architect the tax function for one of the most influential AI companies in the world.

Key facts

What you'll do

Evaluate transactions across the full spectrum of corporate structures, including stock and asset acquisitions, mergers, and acqui-hires, and determine the most tax-efficient structure and path.

Perform rigorous tax due diligence on target companies, identifying exposures, liabilities, and risks in uncertain tax positions while quantifying potential impacts on value.

Draft, negotiate, and review tax provisions in a wide range of transaction documents, including purchase agreements, merger agreements, and related ancillary instruments.

Analyze and plan for post-closing integration activities, focusing on entity rationalization, intercompany restructuring, and the utilization or preservation of tax attributes.

Assess data center investments, build-to-suit arrangements, lease structures, and related infrastructure transactions, coordinating with stakeholders on incentives, credits, and indirect tax issues.

Structure and advise on joint ventures, strategic partnerships, and REIT-related investment vehicles, ensuring alignment with both tax and commercial goals.

Develop and maintain transactions tax playbooks, standardized due diligence checklists, and repeatable processes to scale the function efficiently.

Coordinate closely with the tax compliance and provision teams to ensure clean transaction handoffs, accurate documentation of elections, and consistent reporting positions.

Prepare detailed technical memoranda that explain complex tax positions, support financial statement audit conclusions, and underpin positions taken in tax returns.

Partner with Corporate Development to provide early-stage tax insights that influence deal economics, go/no-go decisions, and negotiation priorities.

Champion the identification and evaluation of tax synergies and value preservation strategies across all deal pipelines.

Communicate complex tax analyses to non-tax stakeholders, balancing depth of technical detail with clarity and actionable recommendations.

Own the documentation of tax positions and risk factors to ensure readiness for audit, review, and regulatory examination.

Support the design of governance frameworks and controls that promote disciplined decision-making and compliance across transactions.

Requirements

JD or CPA.

M&A and transactional tax experience gained at a large law firm, Big 4 M&A tax practice, or in-house transactions tax team.

Strong technical expertise in federal and state tax rules governing corporate transactions, including Section 338, Section 368 reorganizations, and asset and stock acquisitions.

Experience running tax due diligence workstreams and quantifying tax exposures in transaction contexts.

Experience drafting and negotiating tax provisions in M&A transaction documents.

Experience supporting post-acquisition integration from a tax perspective, including entity rationalization and intercompany restructuring.

7-10 years of tax experience, with significant M&A and transactional tax exposure.

LL.M. in Taxation or MST.

Experience providing general tax advisory support, including advising on commercial contracts, operational matters, and cross-functional tax questions.

Experience with joint ventures, partnerships, minority investments, revenue-sharing arrangements and financing transactions.

Experience with REITs, including REIT qualification and tax considerations for REIT joint ventures and real estate investment structures.