Fluidstack
Tax Planning Lead
San Francisco, CA, Remote. Posted 4 months ago
The role
The Tax Planning Lead will run tax due diligence on acquisitions, site and power deals, and JV investments. They will structure acquisitions, joint ventures, and financings across US federal, state, and international tax. The role also involves designing internal restructurings and building a transfer pricing framework.
What you will do
- Run tax due diligence on acquisitions, site and power deals, and JV investments
- Turn due diligence findings into price adjustments, indemnities, and structure changes
- Structure acquisitions, joint ventures, and financings across US federal, state, and international tax
- Design and execute internal restructurings including cross-border reorganizations
- Build the transfer pricing framework across the US, UK, and Europe
- Own state intercompany positions such as apportionment and intercompany charges
- Work alongside deal teams and outside counsel on live transactions
Required qualifications
- Run tax due diligence on acquisitions or investments and translate findings into deal terms
- Structured acquisitions, JVs, or financings across US federal, state, and international tax and written the step plan
- Planned and executed internal restructurings across multiple entities and countries
- Built or rebuilt a transfer pricing framework and defended it with a tax authority
- Handled state intercompany issues across several states
- Worked alongside deal teams and outside counsel on live transactions
- Explain a technical tax position clearly to a non-tax executive
Nice to have
- Advanced tax credentials (CPA, JD, LLM in Tax)
- M&A tax at a Big Four or law firm
- Capital-intensive infrastructure (datacenters, energy, real estate)
- Cross-border reorganizations (§367, F reorganizations)
- Tax modeling and finance systems (Pigment, NetSuite)
About the company
Fluidstack is focused on delivering GWs of compute for AI by acquiring power, designing and building data centers, and operating them. They aim to build civilization-scale infrastructure for AI.