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Duties

WHAT IS THE LBI - Large Business and International 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: Large Business and International Director Treaty and Transfer Pricing Operations WHAT DOES A COMPETENT AUTHORITY ANALYST (TAX TREATY) DO? The position seeks a tax professional for the Treaty Assistance and Interpretation Team (TAIT) within the office of the Treaty and Transfer Pricing Operations (TTPO), under the direction of the Director, Advance Pricing and Mutual Agreement, Large Business and International Division. Incumbent serves as an expert in tax treaty interpretation and application with respect to United States tax treaties. The major responsibilities include providing authoritative advice and assistance on tax treaty matters. 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. Receives and reviews taxpayer requests for assistance in obtaining relief from double taxation including, for example, requests for relief under treaty provisions concerning residency, limitations of benefits, artists, athletes and entertainers, withholding, and all issues other than those involving transfer pricing and related allocation of business profits provisions, to determine if such requests comply with procedural guidelines. Performs a balanced and critical analysis of taxpayer and treaty-partner proposals and performs due diligence to ensure that the facts and circumstances of the taxpayer's case are sufficiently understood and known to arrive at a legally supportable and well-reasoned determination. Evaluates, analyzes, and develops the positions of the United States with respect to complex tax treaty interpretation and assistance issues and other international tax issues, with minimal direct supervision. Conducts independent research and analysis of tax, accounting, treaty, and economic issues and coordinates with IRS subject-matter experts, when necessary. Prepares positions and other memoranda for the U.S. Competent Authority, recommending a course of action based on analysis of the facts of the case, applicable tax law and treaty provisions, and the position of the foreign country.

Requirements

Qualifications

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. You must meet the following requirements by the closing date of this announcement: SPECIALIZED EXPERIENCE: GS-14 LEVEL: You must have 1 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: experience in methods and techniques pertaining to the interpretation and application of tax treaties to analyze and provide assistance to taxpayers requesting relief from double taxation or from taxation that is not in accordance with tax treaties, and to advise internal and external stakeholders on treaty-related issues; experience analyzing and interpreting U.S. tax treaties, the U.S. Model Income Tax Convention and the Organization for Economic Cooperation and Development (OECD) Model Double Taxation Convention; experience in applying Revenue Procedure 2015-40 (Requesting Competent Authority Assistance Under Tax Treaties); and experience in applying the Internal Revenue Code and its regulations to international issues for purposes of tax planning or examinations of multinational entities or high-wealth individuals, particularly with respect to U.S. foreign tax credits, interest allocation rules, and subpart F transactions and arrangements. 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". 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 LBI - Director Treaty and Trans Pric Ops 1111 Constitution Ave NW Washington, DC 20224 US
• Name: (ERC) Employee Resource Center
• Phone: 866-743-5748