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 their deliverables
• Track US legislative and regulatory developments and OECD developments in your areas, assess their impact on our position, and share the analysis with the planning group and Finance leadership
• Work with the tax advisory team, Legal, Accounting, and Treasury to make sure approved planning and integration steps are implemented as designed, including intercompany agreements
• Support responses to IRS and other tax authority inquiries relating to positions you have worked on

Minimum qualifications

• Have deep technical knowledge of the US international tax provisions, including subpart F, NCTI, BEAT, and the foreign tax credit rules, and have applied them in a planning context rather than in compliance alone
• Have working knowledge of subchapter C as it applies to multinational groups, including earnings and profits, stock basis, distributions, and internal reorganizations
• Have led tax planning projects end to end, including scoping, technical analysis, modeling, documentation, and implementation
• Understand how planning positions flow into transfer pricing, the ASC 740 provision, and the US international compliance forms
• Can research a technical question in the Code, regulations, and administrative guidance and write a clear, well supported memorandum
• Can review a tax model built by someone else, identify where the technical assumptions or mechanics are wrong, and explain what needs to change
• Have managed outside advisors, including scoping work, managing budgets, and reviewing their output
• Can run several projects at once with different internal owners and keep each of them moving
• Can reach a defensible recommendation when the facts are incomplete or the guidance is unsettled, and can explain the remaining uncertainty
• Communicate technical tax conclusions clearly to people who are not tax specialists, and work well with colleagues in Legal, Accounting, and Treasury
• Are excited about Anthropic's mission to develop AI that is safe and beneficial

Preferred qualifications

• CPA, JD, or LLM in taxation
• 10-15 years of extensive US international tax experience, for example a combination of public accounting or law firm practice and an in-house role at a multinational technology company
• Experience with post-acquisition integration planning, including step plans and modeling for bringing acquired entities into an existing international structure
• Direct experience with transfer pricing, Pillar Two, or the FDDEI deduction and how they interact with the US international provisions
• Familiarity with the tax rules of the non-US jurisdictions where a US technology company typically operates
• Have working knowledge of partnership tax as it applies to multinational groups, including the formation and funding of joint ventures, allocations and distributions, and how partnership structures interact with the US international provisions
• Experience planning around large cross-border commercial arrangements, such as cloud, compute, or licensing agreements, or standing up entities in new jurisdictions
• Experience with infrastructure or capital-intensive investments, such as data centers, energy, or similar assets, including joint venture and financing structures
• Experience supporting an IRS examination of international positions
• Experience at a company that scaled significantly, or built out its international structure, during your tenure
• Have built or reviewed US international tax models yourself, which tends to make review faster and more precise
• Have used Claude or similar tools in tax research, modeling, or documentation, and have views on where they help and where they do not
• Have mentored or developed other tax professionals