Senior Manager, US Tax Strategy and Planning

About the Role
We're hiring a Senior Manager, US Tax Strategy and Planning to drive US tax planning and advice for Nscale's AI data center infrastructure work. Based in New York City on a hybrid arrangement, you'll report to the US Tax Director in London and work with corporate development, legal, construction, engineering, finance and external advisors.

You'll tackle tax questions arising from live contracts, construction projects, financings and transactions, often before every fact is settled. Your analysis will help non-tax decision-makers act quickly. This is a planning and advisory role, not a return-preparation role: external providers handle US federal and state filings, while you'll inform and review the positions those filings reflect.

What you'll be doing
Transactions and contracts
Advise on tax structuring for acquisitions, reorganizations, cross-border transactions, partnerships, joint ventures and capital markets work.
Lead tax execution from diligence and step plans through transaction agreement review and post-closing integration with corporate development, legal and external counsel.
Analyze Section 382, lease-versus-service characterization of customer contracts and anti-conduit questions on intercompany lending.
Review commercial contracts for sourcing, withholding, transaction tax and contracting-entity consequences, providing actionable mark-ups to deal teams.
Infrastructure and cross-border planning
Work with construction and engineering teams on cost segregation and fixed asset classification for data center build-outs.
Lead or co-own negotiated sales and use tax and property tax incentives, federal energy tax credits and other identified opportunities.
Build and pressure-test models with FP&A and treasury for cost recovery, material book-tax differences and cash tax forecasts.
Coordinate with global tax and finance teams on transfer pricing, intercompany arrangements, BEAT, withholding and funding structures.
Advice, reporting and advisors
Explain tax decisions in plain English to non-tax colleagues and executives, including through board slides, memos and auditor position papers.
Support the compliance and reporting team on ASC 740, tax positions arising from planning, state and local tax matters, incentives and financial statement disclosures without owning the filings.
Scope work with external advisors, review fees and monitor spend against budget.
About You
10+ years of progressive experience in US federal and state taxation; a mix of Big 4 and in-house corporate experience is welcome.
A CPA or equivalent US professional qualification; an advanced tax degree (JD, LL.M. or MST) is helpful but not required.
Strong US corporate and partnership tax knowledge across several areas such as Subchapter K, consolidated returns, cost recovery, interest limitations, NOL and ownership-change analysis, and inbound and outbound international provisions.
Technical expertise in corporate tax, international tax provisions (including BEAT, PFIC and CFC), modeling and cross-border structuring.
Experience managing complex tax projects and explaining technical outcomes to non-tax executives in clear, practical terms.
Judgment when facts are incomplete, timelines are short and commercial pressures compete; you can distinguish a real risk from a theoretical one.
Willingness to work with a UK-headquartered group, including some early-morning overlap with colleagues in the UK.
Experience in data centers, energy, infrastructure, real estate or another capital-intensive sector is helpful, as is work on state and local incentives, energy tax credits, IPO readiness or building an early-stage tax team.