Attorney-Adviser (Tax) - Special Counsel - Inte...

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Duties:

The Special Counsel serves as the legal and technical consultant to the Associate and Deputy Associate Chief Counsels (International) (INTL), on the most difficult, important and complex matters. INTL's responsibilities include legal issues arising out of taxation of U.S. persons with foreign activities (foreign tax credits; taxation of income earned through direct or passive investments, controlled and non-controlled foreign corporations, passive foreign investment companies, unincorporated branch operations and foreign partnerships or trusts; and information reporting obligations), the taxation of foreign persons with U.S. activities (effectively connected income, branch profits tax, determination of U.S. residence and consequences of expatriation, withholding of tax on U.S. source income, the taxation of foreign governments and international organizations and their employees), U.S. taxation relating to U.S. territories, and laws relating to cross-border activities of both domestic and foreign persons (transfer pricing; entity classification; cross-border reorganizations; the source of income and allocation of deductions); taxation of financial products and income from international financial services and insurance activities; foreign currency transactions; international information exchange and summons enforcement; conflict of laws and the application of income tax treaties and international agreements.

As an Attorney-Adviser (Tax) - Special Counsel, your duties will include the following:

• Operate as a critical link between subject matter experts in INTL and other Counsel offices, as well as personnel in Appeals and Examination, with respect to the preparation of technical guidance, international field service, litigation, and strategic programs.
• Draft both legal and non-legal documents ranging from tax advocacy designed for legal practitioners to non- technical/educational materials targeted for more general use. Provide oral and written advice applying the tax laws related to cross- border transactions and activities, including the international provisions of the U.S. revenue laws, and bilateral and multilateral tax treaties and agreements to which the United States is a party. Exercise decision-making skills, including in case or project management. Analyze and interpret complex tax legislation, regulations, and policy matters that impact international tax policies and guidance.
• Ensure that controversies stemming from cross-border transactions and activities are handled consistently with the correct interpretation of international provisions of the United States revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party, and all foreign revenue laws that pertain to or affect tax matters in the United States.
• Render legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning international issues under examination in the audit of returns or in the consideration of claims for refunds or in respect of matters of treaty interpretation; and participate in the preparation of briefs and other materials in connection with U.S. Tax Court litigation involving international matters.
• Prepare or review recommendations concerning the defense, settlement, concession, or appeal of refund suits pending in international cases in the U.S. District Courts or the U.S. Court of Federal Claims; and work with the Department of Justice in connection with preparation of briefs and positions and strategy taken in international appellate litigation.

This is not an all-inclusive list.

Requirements:
Conditions of Employment:

• 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 detailed below by the closing date of this announcement. 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 Attorney-Adviser (Tax) - Special Counsel, you must meet the qualification requirements listed below by the closing of this announcement:

Basic Requirements for Attorney-Adviser (Tax) - Special Counsel:

• 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 years of professional legal tax experience.

Professional Legal Tax Experience is defined as performing legal research and/or legal guidance in federal tax controversy, federal tax litigation, or federal tax consulting. 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 (e.g., 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. (https://ope.ed.gov/dapip/#/home)

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: Recognition of Foreign Qualifications | International Affairs Office (ed.gov) (https://sites.ed.gov/international/recognition-of-foreign-qualifications/)