Duties
WHAT IS THE LARGE BUSINESS AND INTERNATIONALDIVISION?
A description of the business units can be found at:
Vacancies will be filled in the following specialty areas:
Large Business and International Director Treaty and Transfer Pricing Operations, APMA, TAIT
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
Conditions of Employment
- Telework Eligible Positions: Telework eligible positions do not guarantee telework. Employees must meet and sustain IRS telework eligibility requirements (e.g., reporting at least twice a pay period to your assigned Post of Duty (POD)) and supervisor's approval to participate in the IRS Telework Program. Employees must also be within a 200-mile radius of their official assigned post-of-duty (POD) while in a telework status. As a reminder - If you are selected for a position, you are responsible for reporting to your designated POD (location) on the negotiated start date or as directed by management.
- Must be a U.S. Citizen or National and provide proof of U.S. Citizenship. (Birth certificate showing birth in the U.S; Unexpired U.S. Passport; Certificate of Citizenship or Naturalization; or Report of Birth Abroad of a U.S. Citizen (Form FS-240))
- Must successfully complete a background investigation, including a FBI criminal history record check (fingerprint check).
Qualifications
Federal experience is not required. The experience may have been gained in the public sector, private sector or One year of experience refers to full-time work; part-timework 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
OR time of referral:
SPECIALIZED EXPERIENCE: Applicants must have one year of specialized experience at a level of difficulty and responsibility equivalent to the next lower level in the normal line of progression in the Federal Service.
Specialized experience is such that demonstrates 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, as well as generally applicable competent authority agreements, for example, participate in and support Treasury-led teams negotiating tax treaties and other international tax agreements and to develop U.S. Competent Authority positions; experience in applying Revenue Procedures and other Internal Revenue Service procedural guidelines; and experience with the Internal Revenue Code and regulations pertaining to international issues to analyze and provide assistance to taxpayers requesting relief from double taxation.
For more information on qualifications please refer to .
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 .
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 for Foreign Education Credentialing instructions.
Additional information
- A 1-year probationary period is required.
- Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
- We may select from this announcement or any other source to fill one or more vacancies. Additional jobs may be filled.
- This is a bargaining unit position.
- Tour of Duty: Day Shift - Start and stop times between 6:00 a.m. and 6:00 p.m.
- Alternative work schedule, staggered work hours or telework may be available.
- In the event that a building is closed due to rent management, new hires may be placed in a local commuting location.
- Relocation expenses - No
- The employment of any candidate selected for this position, including a current employee or a new hire, selected for this position may be conditional upon classification and/or audit of federal tax returns. This audit may include up to 2 years of returns.
- File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on.
- Obtain and use a Government-issued charge card for business-related travel.
Please consider each location carefully when applying. If you are selected for a position at one of your location selections, that location will become your official post of duty.
If the position(s) are no longer needed prior to the closing date, this announcement may be closed early.
This is an open announcement which will be used to fill vacancies in the locations listed as they become available for the next 6 months contingent upon funding and space requirements. Applicants must apply and/or update their applications by 11:59 pm ET at the close of the following cutoff dates to be considered: Cutoff date(s):
4/29/2024, 7/29/2024, 10/29/2024. This announcement may be amended to include additional cut-off dates within the
6 month period if needed, not later than 10 days prior to the additional cut-off date(s). Eligible applicants who apply by the initial cut-off date, will be referred in score order.
If additional vacancies exist, remaining applicants will be considered in score order as needed. Selections from this announcement may be made no later than (NLT)
1/29/2025.
A career with the U.S. government provides employees with a comprehensive benefits package. As a federal employee, you and your family will have access to a range of benefits that are designed to make your federal career very rewarding. .
Eligibility for benefits depends on the type of position you hold and whether your position is full-time, part-time or intermittent. Contact the hiring agency for more information on the specific benefits offered.
Required Documents
The following documents are required and must be provided with your application. All application materials, including transcripts, must be in English.
- Online Application - Questionnaire
- Education - See Education Section above
- Registration/License (If Applicable) - active, current registration/license
- High School Diploma (or equivalent) - If you are 16 or 17 years of age, you MUST submit documentation of graduation from high school (or equivalent); OR completion of a formal vocational training program; OR statement from school authorities agreeing with your decision to pursue employment rather than continuing your education.
Please note that if you do not provide all required information, as specified in this announcement, you may not be considered for this position (or may not receive the special consideration for which you may be eligible).
How to Apply
This Direct Hire Public Notice is to gather applications that may or may not result in a referral or selection. Your application will remain active through the open period of this Public Notice. Applicants will be referred on a first in, first out basis. Those applicants who are applying earlier in the process will stand a much better chance of being referred for consideration in the selection process.
The following instructions outline our application process. You must complete this application process and submit any required documents by 11:59 p.m. Eastern Time (ET) on 10/29/2024 in this announcement. We are available to assist you during business hours (normally 8:00 a.m. - 4:00 p.m. ET, Monday - Friday). If applying online poses a hardship, please contact us by noon ET on 10/29/2024.
To preview the Application Questionnaire, please click the following link:
- To begin the application process, click the "Apply Online" button.
- You will be re-directed to USA STAFFING to complete your application process; answer the online questions and submit all required documents. (To submit supporting documents, import documents from USAJOBS to the appropriate document types. If the document you need was not imported from USAJOBS, you may upload it directly into this application. To protect your privacy, we suggest you first remove your SSN).
- To complete, you must click the "Submit Application" button prior to 11:59 PM (ET) on 10/29/2024.
To update your application, including supporting documentation, at any time during the announcement open period, return to your USAJOBS account (). There you will find a record of your application, the application status, and an option to Update Application. This option will no longer be available once the announcement has closed.
To verify the status of your application both during and after the announcement open period, log into your USAJOBS account: . All of your applications will appear on the
Welcome page. The application record in your USAJOBS account provides an
Additional Application Information page that provides information regarding the documentation you submitted and any correspondence we have sent related to this application. The
Application Status will appear along with the date your application was last updated. For information on what each
Application Status means, visit: . Agency contact information
IRS Austin External
Email
Address
LBI - Director Treaty and Trans Pric Ops
1111 Constitution Ave NW
Washington, DC 20224
US
Next steps
Treasury believes in a working environment that supports inclusion; please view our reasonable accommodation policies and procedures at . We will provide reasonable accommodation to applicants with disabilities on a case-by-case basis; please contact us if you require this for any part of the application and hiring process.
Once your application package and online questionnaire is received you will receive an acknowledgement email. You are responsible for checking status updates and notifications in USAJOBS. Hard copy notifications will not be sent to you. You may check the status of your application for this position at any time by logging onto the USAJOBS "My Account" tab and clicking on "Application Status." For a more detailed update of your application status, you may click on "more information." Please notify us if your contact information changes after the closing date of the announcement. If your email mailbox is full or blocked (SPAM) you may not receive important communication that could affect your consideration for this position.
Fair & Transparent
The Federal hiring process is set up to be fair and transparent. Please read the following guidance.
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Internal Revenue Service
$129,134.00 - $191,900.00 / yr
April 24, 2024