Director, US International Tax Planning

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 alternatives, and leading follow-on planning for the combined structure
• Draft technical memoranda and maintain documentation that would support each planning position on examination, and work with the provision team on ASC 740 treatment, including uncertain tax positions
• Partner with tax compliance and transfer pricing so that your projects are reflected accurately in intercompany pricing, the provision, and the US international filings (Forms 5471, 8858, 8991, 8992, 1118, and related), and review the international portions of the US return as a subject matter expertise
• Scope, budget, and manage work performed by outside advisors on your projects, and review the