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Duties

WHAT IS THE LARGE BUSINESS/INTERNATIONAL-LBI DIVISION? A description of the business units can be found at: https://www.jobs.irs.gov/about/who/business-divisions The position is located in the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS). The International Transfer Pricing Specialist is an expert in the analysis and application of relevant law to significant international tax compliance issues relating to Internal Revenue Code (IRC) §482 and corresponding Treasury Regulations. The incumbent collaborates directly with IRS Examination Teams relating to the development of audit plans, fact gathering, and the preparation of position papers, including Forms 5701 (Notice of Proposed Adjustment). The incumbent participates as a technical expert in tax compliance examinations and provides expert advice that may impact tax policy and the International Examination Program as a whole. The incumbent may participate as a member of IRS teams, including but not limited to Practice Networks (PNs), and on other projects or assignments focused on specific international tax issues. The incumbent may coordinate or participate in a national tax compliance task force. Assists Examination Teams in planning, directing, and coordinating the examination of international transfer-pricing issues. The incumbent serves on a consulting basis for other Examination and International Specialists, Counsel Attorneys, Appeals Officers, and Revenue Agents regarding the examination of transfer-pricing issues and transactions. The incumbent may also be assigned to work closely with IRS Examination Teams on multiple examinations simultaneously. Collaborates and coordinates with Examination and International Specialists, Counsel Attorneys, Appeals Officers, and Revenue Agents to leverage and expand international issue expertise throughout the IRS, and to ensure consistent application and interpretation of international tax law. The incumbent regularly participates in groups focused on international issues including, but not limited to, PNs; and interacts regularly with personnel in the Advance Pricing and Competent Authority programs (APMA). Participates in long-term projects involving the development of new auditing techniques, work practices, and training programs for Examination Specialists, Counsel Attorneys, Appeals Officers, and Revenue Agents. The incumbent may be assigned to develop and conduct training sessions and hold periodic meetings with IRS personnel at national and local office levels to review all matters relating to international transfer-pricing. Performs research and analysis of tax issues involving economics, transfer pricing, and valuation related to specific taxpayers or across taxpayers and industries. Provides feedback, technical expertise, and recommendations to IRS management and IRS Counsel on transfer-pricing issues. The International Transfer Pricing Specialist identifies and discusses any issues that require technical advice, field service advice, or industry-wide coordination procedures to be followed. Meets with taxpayers, industry representatives, members of professional associations, and national tax administrators to explain IRC §482 transfer-pricing issues, and to seek alternate resolution opportunities. Also provides specialized assistance to other governmental agencies and national tax administrations regarding tax matters relating to transfer-pricing issues. Coordinates, leads, or collaborates with the national analyses of tax issues involving significant international transfer-pricing transactions related to specific taxpayers or across taxpayer, industry, and international boundaries.

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 with application of tax law to transfer pricing projects, transactions, and controversies, including application of the Internal Revenue Code, corresponding Treasury Regulations, tax treaties, Court decisions and the Organization for Economic Cooperation and Development (OECD) Guidelines related to transfer pricing between US and foreign related parties including transfers of tangible and intangible property, high value services, asset valuations, and risk allocation; Applying auditing techniques to multiple, interrelated transfer pricing issues as listed above on large corporate returns. Performing research and analysis of transfer pricing issues; conducting various kinds of audit steps verifying taxpayers' economic structure, business practices and functions; reviewing and analyzing economic, financial, operational and tax data to determine the existence of a potential transfer pricing issue; performing analyses to determine and/or evaluate tax reporting of intercompany transactions; providing technical advice concerning transfer pricing issues on cases; providing advice and recommendations to other examiners within issue networks during workshops and other knowledge sharing forums. Experience preparing and delivering written and oral communications to explain and defend the Government's position related to transfer pricing; holding conferences with taxpayers, their representatives and others to present and discuss transfer pricing positions and analysis; Experience serving, where necessary, as a qualified witness for the government in litigation cases. Experience assisting on competent authority cases or advance pricing agreements; correlative adjustments, set offs, or commensurate with income; and experience with treaty partners such an exchange of Information (EOI), Joint Audit, or International Compliance Assurance Program (ICAP). AND MEET TIME IN GRADE (TIG) REQUIREMENT: For positions above the GS-05, applicants must meet applicable time-in-­grade requirements to be considered eligible. One year (52 weeks) at the next lower grade level is required to meet the time-in-grade requirements for the grade you are applying for. 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.

• Note: If substituting Superior Academic Achievement (SAA) for experience at the GS-7 level, please note that grade-point averages are rounded to one decimal place. For example, 2.95 will round to 3.0 and 2.94 will round to 2.9. The Qualifications requirements above will reflect if SAA is accepted for this position and the online questionnaire will offer the option to select SAA as a qualifying response.

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 Large Business and International 1111 Constitution Ave NW Washington, DC 20224 US
• Name: (ERC) Employee Resource Center
• Phone: 866-743-5748
• Email: [email protected]