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.

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