Infrastructure Tax Lead

Role Overview

• Serve as the embedded tax partner to Infrastructure team on deal intake: gather facts on site specs, counterparty structure, commercial terms, and timing; provide structure review and term-sheet input early enough to shape the deal
• Lead Incentives workstream on state and local incentives, sales and use exemptions, and site selection tax input; ensure incentive commitments and compliance obligations are reflected in the integrated tax position for each site
• Partner with Tax Transactions and Tax Planning teams on lease characterization, entity structure, and contract tax provisions; own the tax read on lease-versus-purchase, and treatment across a portfolio of non-standard structures
• Lead after-tax deal economics: bonus depreciation modeling on large-scale buildouts, NOL utilization, and scenario analysis; partner with Tax Planning and FP&A to ensure tax assumptions are reflected accurately in deal approval packages
• Coordinate with Technical Accounting on lease-versus-purchase treatment, consolidation questions, capitalization policy, and book-tax differences across a range of deal structures
• Stand up and maintain 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
• Partner with transfer pricing on policy for the infrastructure footprint: intercompany compute pricing, benchmarking, and documentation that will withstand scrutiny as intercompany flows scale
• Partner with the tax provision team on quarterly impact of new structures and deferred tax positions; ensure there are no surprises between deal close and quarter close
• Build and maintain infrastructure tax playbooks, issue-spotting checklists, and internal processes so the function scales with deal volume rather than linearly with headcount

Requirements

• 12+ years of tax experience with significant exposure to datacenter, REIT, or large-scale real estate tax planning, including meaningful international range
• JD or CPA required; LL.M. in Taxation or MST a plus
• Deep technical command of lease characterization and Section 467, bonus depreciation modeling on capital-intensive buildouts.
• Experience standing up and maintaining entity structures across multiple jurisdictions, including contemporaneous documentation and operationalizing with local finance, legal, and accounting teams
• Working fluency in cross-border withholding on intercompany and third-party financing, permanent establishment analysis, and debt-versus-equity characterization
• Track record of owning the integrated tax position across a portfolio of deals — not advising on one issue at a time, but carrying the thread across functions from term sheet to post-close
• Demonstrated ability to operate as a cross-functional coordinator: comfortable running point across Legal, Accounting, FP&A, and business teams without formal authority over any of them
• Exceptional written and verbal communication — able to translate complex tax positions into clear guidance for Infrastructure leadership and deal teams
• Comfort with ambiguity and a track record of building processes from scratch in a fast-moving environment

Benefits

• Competitive compensation and benefits
• Optional equity donation matching
• Generous vacation and parental leave
• Flexible working hours
• Lovely office space in which to collaborate with colleagues