Job opening: General Attorney (Tax) Senior Technical Reviewer Branch 6
Salary: $160 458 - 191 900 per year
Published at: May 20 2024
Employment Type: Full-time
Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. Please click "Learn more about this agency" to find out more about Chief Counsel's various offices, to view some of the workplace attributes that Chief Counsel's workforce rates most favorably, and to hear from employees themselves.
Duties
This position is located in Washington, D.C., in the office of the Associate Chief Counsel (International, Branch 6). The principal subject matter areas of the branch include all transfer pricing issues and related regimes and penalties, e-commerce, the section 250 deduction for foreign derived intangible income and global intangible low-taxed income, certain sourcing provisions, and advice to the APMA Program and Treaty and Transfer Pricing Operations. The Senior Technical Reviewer (STR) serves as a technical expert with respect to the tax areas relating to the functions of Branch 6. In addition, the STR is responsible for the assignment and review of the cases for some of the attorneys within the Branch; and, as assigned, may perform other administrative/management tasks within the Branch. The Senior Technical Reviewer in this position functions as an Assistant to the Branch Chief.
As a General Attorney (Tax) - Senior Technical Reviewer, you will:
Act as a legal and technical consultant to the Branch Chief, the Deputies Associate Chief Counsel (International), the Associate Chief Counsel (International), and, as assigned, to other officials in the Office of Chief Counsel on some of the most important professional legal and policy matters concerned with the work of the Branch, or that may affect the work of other Branches of the office, or other components of the Office of Chief Counsel. Such matters involve research on complicated legal problems and the development of recommendations regarding the positions to be taken by the Branch and the Office.
Act as a reviewer and, in some cases as the initiating attorney, on projects involving the development and drafting of Internal Revenue legislation and regulations, considering recommendations for enactment of legislation and the promulgation of regulations, and the issuance of private letter rulings, revenue rulings, technical advice memoranda, general legal advice memoranda, and other guidance.
Act as the principal attorney in charge of recommending the policies and developing the procedures and regulations implementing new or amended legislation for specific areas of tax law and is responsible for ensuring that these policies, procedures, and regulations are consistent with the intent of the law and are administratively sound, efficient, and economical in operation.
Perform activities in the subject area of the Branch including legal assistance, document review, appellate recommendations, and litigation support. Many of the issues presented for decision are submitted after extensive consideration in the field and elsewhere. Problems presented cover a broad range of tax law issues requiring interpretation of the Internal Revenue Code, tax regulations, published rulings, court cases, and other technical materials. Make recommendations on the need for initiating, consolidating, or eliminating programs and projects. Act as project manager, assigns (in consultation with the Branch Chief) work to the attorneys and specialists within the Branch, advises them on the approach to take, reviews work product, and provides the Branch Chief with performance feedback of work performed.
As needed, represent the IRS in conferences with taxpayers and their representatives. In this connection, the STR analyzes the transactions or issues involved in light of the Internal Revenue Code and applicable regulations, examines the data submitted (such as court exhibits and briefs), questions taxpayers or their representatives, and makes a determination or recommendation for the IRS.
As necessary, participate in the resolution of complex technical problems presented by taxpayers or their representatives and give advice on important technical, legal, and policy matters to the Associate Chief Counsel (International), the Deputies Associate Chief Counsel (International), and other Office of Chief Counsel officials.
As appropriate, speak or engage in panel discussions before business and professional groups on technical and legal matters relating to the work of the Branch. As required, and also in cases in which the Branch Chief is absent, the STR substitutes for the Branch Chief and performs the full range of duties of that position. In situations where the signature by a higher official is not necessary, may take final action with respect to work prepared in the Branch. Otherwise, may make decisions for referral to higher levels of review.
Perform other duties as assigned by management.
Requirements
- Refer to "Additional Information"
- Click "Print Preview" to review the entire announcement before applying.
- Must be a U.S. Citizen or National
Qualifications
In order to qualify, you must meet the education and/or experience requirements described below. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.
To qualify for this position of General Attorney (Tax) - Senior Technical Reviewer, you must meet the qualification requirements listed below by the closing of this announcement:
Basic Requirements for General Attorney (Tax) - Senior Technical Reviewer:
Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; AND
Applicants must be an active member in good standing of the bar of a State, U.S. Commonwealth, U.S. territory, the District of Columbia, or the Commonwealth of Puerto Rico.
GS-15 Experience Requirements:
1 year of general professional legal experience from any area of expertise; plus
3 year(s) of professional legal tax experience
Professional Legal Tax Experience is defined as: Knowledge and expertise in transfer pricing and related regimes and penalties, the deduction for foreign-derived intangible income, classification of certain digital content and cloud transactions, and special sourcing provisions under section 863 related to inventory sales, transportation income, space and ocean activities, and international communications, and provides specialized assistance to Treaty and Transfer Pricing Operations.
At least one year of this experience must be equivalent to the work performed at the next lower grade/level position in the federal service (GS-14).
Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience.
Education Substitution: An LL.M. degree in the field of the position (tax, GLS-related, orP&A- FOIA/Disclosure related field) may be substituted for the one year of the general legal experience listed above.
Experience refers to paid and unpaid experience, including volunteer work done through National Service programs (e.g., Peace Corps, AmeriCorps) and other organizations (e.g., professional; philanthropic; religious; spiritual; community; student; social). You will receive credit for all qualifying experience, including volunteer experience. 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.
Education
For positions with an education requirement, or if you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. An official transcript will be required if you are selected.
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: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. For further information, visit:
http://www.ed.gov/about/offices/list/ous/international/usnei/us/edlite-visitus-forrecog.html.
Contacts
- Address Office of Chief Counsel, IRS
Staffing and Classification Branch
1111 Constitution Ave, NW
Washington, DC 20224
US
- Name: Malva Trowser
- Phone: 469-801-0076
- Email: [email protected]