Senior Manager, Tax - Provisions

About the role

ABOUT FLUIDSTACK We exist to make humanity more free. For most of human history, you farmed or you starved. Technology gave people more time for the things they wanted to do, instead of things they had to do. Powerful AI will be the biggest lever for human choice we've ever built - but only if models are aligned with what humanity actually wants. There are groups building AI who don't share these goals. Whoever deploys frontier compute infrastructure fastest will decide whether AI expands human freedom or shrinks it. We're singularly focused on delivering 10 to 100s of GWs of compute faster than anyone else, rethinking every layer of the stack. We acquire power, design and build data centers, and operate them - with teams spanning hardware and software. Speed and scale are our key differentiators. Come be a part of building civilization-scale infrastructure for AI. We hire people who care deeply about this problem space. If that is you, please apply! HOW WE OPERATE - Be a barrel. Full autonomy. Own things end to end, take on scope without being asked, no permission required to operate outside your core role. - Insane urgency. We drive everything forward as fast as possible. - Reason from first principles. Challenge every assumption. Zero analogy thinking, no egos, the best idea wins. - Love of the game. The frontier of AI is the most interesting problem of our time. We put in long hours at high intensity to push the frontier forward. - Build something that actually matters. If you're going to spend your time, spend it on something that matters to the world. THE TAX TEAM Examples of key problems the team is working on - Build a tax function for a company scaling to tens of gigawatts. Provision, compliance, planning, and transfer pricing all get designed at once, with the appropriate controls built in from day one rather than bolted on. - Structure deals at the speed the Commercial team signs them. Every site, power deal, and JV carries federal, state, and cross-jurisdiction tax consequences, and the structure must be settled at the LOI, not discovered after signing. - Run a multinational group across seven countries and a growing list of US states. Entity structure, intercompany pricing, and cash movement across the US, UK, and Europe must hold up under audit while the footprint doubles. - Make tax a design input to the business, not a year-end reconciliation. Site selection, financing, and entity decisions get modeled for tax before they're made, so the answer shapes the deal instead of reacting to it. ROLE SCOPE - Run tax due diligence on acquisitions, site and power deals, and JV investments from LOI to signing, and turn the findings into price adjustments, indemnities, and structure changes before the documents are final. - Structure acquisitions, joint ventures, and financings across US federal, state, and international tax, including entity selection, step plans, and the positions that have to survive an audit. - Design and execute internal restructurings as the group adds entities, states, and countries, including cross-border reorganizations and the intercompany agreements and capitalization that come with them. - Build the transfer pricing framework from the ground up across the US, UK, and Europe: intercompany agreements, pricing policies, benchmarking, and documentation. - Own the state intercompany positions, such as apportionment, related-party addbacks, and intercompany charges, as the company builds datacenter sites across multiple US states. WHAT WE'RE LOOKING FOR The below is a starting point. We always make space for exceptional people, so if you don't fit this role exactly, tell us where you would https://jobs.ashbyhq.com/fluidstack/05c2e69c-42f9-4fcb-9cf0-a467aaf98f1c. - You've run tax due diligence on acquisitions or investments and translated what you found into deal terms: purchase price adjustments, indemnities, escrows, or a different structure. - You've structured acquisitions, JVs, or financings across US federal, state, and international tax and written the step plan that someone else then executed. - You've planned and executed internal restructurings across multiple entities and countries and held the positions under audit. - You've built or rebuilt a transfer pricing framework rather than maintaining one, from pricing policy through benchmarking and documentation, and defended it with a tax authority. - You've handled state intercompany issues across several states, including apportionment, related-party expense addbacks, and intercompany service charges. - You've worked alongside deal teams and outside counsel on live transactions and delivered the tax answer on the deal's timeline rather than your own. - You explain a technical tax position clearly enough that a non-tax executive can make a decision on it. - Bonus: 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). We are committed to pay equity and transparency. Fluidstack is an Equal Employment Opportunity Employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, sexual orientation, gender identity, disability and protected veterans’ status, or any other characteristic protected by law. Fluidstack will consider for employment qualified applicants with arrest and conviction records pursuant to applicable law. You will receive a confirmation email once your application has successfully been accepted. If there is an error with your submission and you did not receive a confirmation email, please email careers@fluidstack.io with your resume/CV, the role you've applied for, and the date you submitted your application-- someone from our recruiting team will be in touch.