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Duties

WHAT IS THE APPEALS DIVISION? A description of the business units can be found at: https://www.jobs.irs.gov/about/who/business-divisions Vacancies will be filled in the following specialty areas: Independent Office of Appeals: Specialized Exam Programs & Referrals/Area 11 The following are the duties of this position at the full working level. If this vacancy includes more than one grade and you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and receive training to help you grow in this position. Conducts Appeals conferences for the settlement/resolution of the largest and most complex international tax cases in which taxpayers have appealed determinations made by the Service or have filed petitions with the U.S. Tax Court for redetermination of tax liability. Cases typically concern large, complex businesses, including those with extensive subsidiaries, diversified activities, multiple partners and national or international scope of operations. Receives cases and works issues which have been referred by Appeals management when the complexity of the international tax issues warrants the services of an International Specialist. Reviews international case files, supporting documents, and other information germane to the determination of tax liability. Analyzes case files to determine issues of fact and law. As needed, obtains and evaluates expert testimony or information in highly technical areas such as engineering, finance, science, art, etc. to resolve complex valuation issues. Reconciles apparent factual discrepancies by further investigation, reconstruction, and/or the determination of the interpretation most consistent with all available evidence. Conducts extensive research and analysis of international tax issues to determine and apply the law to the highly complex factual and policy issues presented. Exercises a high degree of judgment in conducting original and creative legal research to obtain a reasonable balance of conflicting interests in determining a resolution. Serves as an expert in determining a final settlement on cases where the law is unclear: laws and regulations may be highly subjective, obscure or conflicting, or case law may be conflicting, lack precedent or clear interpretation. In such instances, determines the appropriate resolution for large dollar or sensitive issues based upon relevant factors including reasonableness, adjudication trends and settlement practices. May raise alternative arguments when appropriate. Serves as an "in-house" expert and/or office liaison on international tax issues where there is little or no previous interpretation of statutory provisions, laws and regulations are highly subjective, precedents are nonexistent, obscure or conflicting, and there are significant amounts of tax at issue. Provides assistance, information, and guidance on international tax issues to Team Case Leaders, Appeals Officers, Appeals Tax Computation Specialists, and other technical staff. Reviews proposed settlements of coordinated issues and conveys concurrence or disagreement. Disagreements will be conveyed in writing. When appropriate, serves as either a lead instructor or an instructor for courses or sessions addressing international tax issues.

Requirements

Qualifications

You must meet the following requirements by the closing date of this announcement: SPECIALIZED EXPERIENCE: GS-14 You must have one year of specialized experience at a level of difficulty and responsibility equivalent to the GS-13 grade level in the Federal service. Specialized experience for this position includes all of the following: Experience applying professional accounting principles, theory, and practices to analyze and interpret accounting books, records, or systems specifically to determine the effect on tax liabilities or financial statements; Experience using accounting or legal knowledge of tax implications to make financial or business decisions; Experience recognizing and assessing the complexity of accounting or legal issues; Experience applying professional legal principles, theory, and practices to analyze and interpret legal issues specifically to determine effect on tax liabilities or financial statements; Interpreting the law in situations where there are uncertainties or conflicts in statutes, regulations, case law, precedence or other guidance to determine and apply the appropriate intent of the law in tax situations; Experience conducting legal research and applying the law to tax situations; Familiar with litigation procedures and making judgments involving matters of law particularly as they relate to resolving tax disputes. In addition to the above you must have experience reviewing analyzing tax treaties between the United States and foreign governments to apply and resolve cases relevant to tax laws in foreign countries, economic theory, exchange rates, contract laws, immigration laws, and bank secrecy laws. Experience in applying tax and accounting principles in the resolution of tax disputes. Such topics may include one or more of the following: shifting of income (through improper pricing or transfer of intangibles), foreign tax credits, Subpart-F, organizational restructuring/cross border mergers and acquisitions involving foreign entities, foreign corporation distributions including liquidations, repatriations, and dividend distributions, permanent establishment issues, effectively connected income and proper sourcing of income, determining assessment and abatement of international penalties and Title 31 penalties. AND MEET TIME IN GRADE (TIG) REQUIREMENT: You must meet applicable TIG requirements to be considered eligible. To meet TIG for positions above the GS-05 grade level, you must have served at least one year (52 weeks) at the next lower grade (or equivalent) in the normal line of progression for the position you are applying to. Advancement to positions up to GS-05 is permitted if the position to be filled is no more than two grades above the lowest grade held within the preceding 52 weeks. AND TIME AFTER COMPETITIVE APPOINTMENT: By the closing date (or if this is an open continuous announcement, by the cut-off date) specified in this job announcement, current civilian employees must have completed at least 90 days of federal civilian service since their latest non-temporary appointment from a competitive referral certificate, known as time after competitive appointment. For this requirement, a competitive appointment is one where you applied to and were appointed from an announcement open to "All US Citizens". Federal experience is not required. The experience may have been gained in the public sector, private sector or Volunteer Service. One year of experience refers to full-time work; part-time work is considered on a prorated basis. To ensure full credit for your work experience, please indicate dates of employment by month/year, and indicate number of hours worked per week, on your resume. For more information on qualifications please refer to OPM's Qualifications Standards.

Education

A copy of your transcripts or equivalent documentation is required for positions with an education requirement, or if you are qualifying based on education or a combination of education and experience. An official transcript will be required if you are selected. If the position has specific education requirements and you currently hold, or have previously held, a position in the same job series with the IRS, there is no need to submit a transcript or equivalent at this time. Applicants are encouraged, but are not required, to submit an SF-50 documenting experience in a specific series.

A college or university degree generally must be from an accredited (or pre-accredited) college or university recognized by the U.S. Department of Education. For a list of schools which meet these criteria, please refer to Department of Education Accreditation page.

FOREIGN EDUCATION: Education completed in foreign colleges or universities may be used to meet the requirements. You must show proof the education credentials have been deemed to be at least equivalent to that gained in conventional U.S. education program. It is your responsibility to provide such evidence when applying. Click here for Foreign Education Credentialing instructions.

Contacts

• Address Appeals - Specialized Exam Prog and Ref 1111 Constitution Ave NW Washington, DC 20224 US
• Name: (ERC) Employee Resource Center
• Phone: 866-743-5748