Description
We are seeking an experienced Infrastructure Tax Lead to join our team. As an Infrastructure Tax Lead, you will be responsible for owning tax end-to-end across our compute infrastructure portfolio, sitting at the point of deal flow, embedded with the Infrastructure team, and coordinating across Legal, Technical Accounting, FP&A, International Tax, Transfer Pricing, Provision, and Incentives.
Key responsibilities include:
- Serving as the embedded tax partner to Infrastructure team on deal intake: gathering facts on site specs, counterparty structure, commercial terms, and timing; providing structure review and term-sheet input early enough to shape the deal
- Leading Incentives workstream on state and local incentives, sales and use exemptions, and site selection tax input; ensuring incentive commitments and compliance obligations are reflected in the integrated tax position for each site
- Partnering with Tax Transactions and Tax Planning teams on lease characterization, entity structure, and contract tax provisions; owning the tax read on lease-versus-purchase, and treatment across a portfolio of non-standard structures
- Leading after-tax deal economics: bonus depreciation modeling on large-scale buildouts, NOL utilization, and scenario analysis; partnering with Tax Planning and FP&A to ensure tax assumptions are reflected accurately in deal approval packages
- Coordinating with Technical Accounting on lease-versus-purchase treatment, consolidation questions, capitalization policy, and book-tax differences across a range of deal structures
- Standing up and maintaining datacenter entity structures across jurisdictions: entity formation, operationalization with local teams, contemporaneous documentation, withholding on cross-border financing, permanent establishment risk, and debt-versus-equity characterization
- Partnering with transfer pricing on policy for the infrastructure footprint: intercompany compute pricing, benchmarking, and documentation that will withstand scrutiny as intercompany flows scale
- Partnering with the tax provision team on quarterly impact of new structures and deferred tax positions; ensuring there are no surprises between deal close and quarter close
- Building and maintaining infrastructure tax playbooks, issue-spotting checklists, and internal processes so the function scales with deal volume rather than linearly with headcount
If you have 12+ years of tax experience with significant exposure to datacenter, REIT, or large-scale real estate tax planning, including meaningful international range, and a JD or CPA, you may be a good fit for this role.
Strong candidates may also have Big 4 or law firm experience in a datacenter, REIT, or infrastructure tax practice, in-house tax experience at a hyperscaler, cloud provider, or large-scale datacenter operator, hands-on transfer pricing experience for intercompany services or compute, including benchmarking and documentation, experience with the owner-operator transition, background in state and local incentives, economic development negotiation, or site selection tax, experience with non-US datacenter tax regimes and cross-border infrastructure structures, and existing relationships with datacenter developers, REIT tax counsel, or Big 4 infrastructure tax teams.
The annual compensation range for this role is $300,000-$370,000 USD.