Attorney-Advisor (Tax) Special Counsel

Internal Revenue Service
$151,894.00 - $191,900.00 / yr
United States, California, San Francisco
Oct 15, 2024
Duties The Special Counsel supports the Deputy Associate Chief Counsel (Controversy & Litigation) and the Associate Chief Counsel (International) ("International") in all matters involving controversy and litigation, including maintaining close working relationships with the other Chief Counsel Divisions, the Internal Revenue Service (IRS) Divisions, and the Department of Justice. International's objectives include advising government stakeholders in all matters involving international tax controversy and litigation, including against regulation challenges and issues of first impression under provisions of the Tax Cuts and Jobs Act, Inflation Reduction Act, and regulations under each, as well as important, newly arising issues under longstanding law, such as transfer pricing, treaty interpretation, and common law doctrines, and the application of the foregoing to aggressive tax planning. International provides technical guidance to the IRS, other Chief Counsel Divisions, and the DOJ to support the enforcement of tax laws involving cross-border transactions and activities. The Special Counsel works closely with the branches within International (which are comprised of groups of attorneys specializing in particular areas of international tax). As an Attorney-Advisor (Tax) Special Counsel, you will: 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. Operate as a critical link between subject matter experts in the International office 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. Ensure that controversies stemming from cross-border transactions and activities are developed and handled consistently with the correct interpretation of international provisions of the U.S. 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 works 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-Advisor (Tax) Special Counsel you must meet the qualification requirements listed below by the closing of this announcement: Basic Requirements for Attorney-Advisor (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 year(s) of professional legal tax experience Professional Legal Tax Experience is defined as: Litigation and controversy experience involving the taxation of cross-border transactions and activities in proceedings before IRS Exam, IRS Independent Office of Appeals, and/or in the U.S. Tax Court, the U.S. Court of Federal Claims, the United States District Courts, and/or the U.S. Courts of Appeals. 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) 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 . 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: Additional information We may select from this announcement or any other source to fill one or more vacancies. Relocation expenses are not authorized. This is a non-bargaining unit position. We offer opportunities for telework. We offer opportunities for flexible work schedules. The salary range indicated in this announcement covers multiple locality areas. Your salary will be adjusted based on the post of duty for which you are selected. Conditions of Employment Continued: Subject to a 1-year trial period (unless already completed). Subject to a 1-year supervisory or managerial probationary period (unless already completed). Subject to a Tenure Commitment of up to 3 years. Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer. Obtain and use a Government-issued charge card for business-related travel. File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on. Undergo an income tax verification. The employment of any candidate, 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. This position requires that the successful candidate undergo personnel vetting, which includes a background investigation and enrollment upon onboarding into "Continuous Vetting." Enrollment in Continuous Vetting will result in automated record checks being conducted throughout one's employment with Treasury. The successful candidate will also be enrolled into FBI's Rap Back service, which will allow Treasury to receive notification from the FBI of criminal matters (e.g., arrests, charges, convictions) involving enrolled individuals in near real-time. There are three key documents that contain important information about your rights and obligations. Please read and retain these documents: 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 A complete application includes 1. A resume, 2. Vacancy question responses, and 3. Submission of any required documents. 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). All applicants are required to submit a resume either by creating one in USAJOBS or uploading one of their own choosing. (Cover letters are optional.) To receive full credit for relevant experience, please list the month/year and number of hours worked for experience listed on your resume. We suggest that you preview the online questions, as you may need to customize your resume to ensure that it supports your responses to these questions. Please view . In addition, applicants are required to submit: An unofficial or official transcript(s) for your J.D. degree or LL.M. degree (an official transcript is required if you are selected) An 8-10 page legal writing sample A memorandum of interest summarizing your interest in the position Current Chief Counsel Employees are also required to submit: A copy of your most recent, signed, completed annual performance appraisal which includes the final rating. If it is not dated within the last 12 months or if you have not received a performance appraisal, please explain why in your application A Supervisory Report for Non-Supervisory Positions (Senior Counsel Only) (ERB Form 1-88a, Rev. 4-11) regarding your suitability for the position as completed by your current supervisor. You are responsible for notifying your supervisor that this report must be received no later than five workdays after the closing date of this announcement. Education Documentation: 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. See "Education" for more details. Certificate of Good Standing: A certified original copy of your certificate of good standing from your State Bar will be required if you are selected. VETERANS' PREFERENCE DOCUMENTATION: There is no formal rating system for applying veterans' preference to attorney appointments in the excepted service; however, the Office of Chief Counsel considers veterans' preference eligibility as a positive factor in attorney hiring. If you are claiming veterans' preference, you must submit a copy of your Certificate of Release or Discharge from Active Duty, DD-214 (Member 4 copy), or other official documentation from a branch of the Armed Forces or the Department of Veterans Affairs showing dates of service and type of discharge. Ten-point preference eligibles must also submit an , along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference, view . If you are relying on your education to meet qualification requirements: Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from . Failure to provide all of the required information as stated in this vacancy announcement may result in an ineligible rating or may affect the overall rating. How to Apply 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 10/17/2024 and/or cut-off dates in this announcement. We are available to assist you during business hours (normally 7:30 AM to 4:00 PM.ET, Monday - Friday). To preview the Application Questionnaire, please click the following link: If you require a reasonable accommodation for a disability or medical condition during any part of the application and hiring process, please contact Kimberly Johnson, Reasonable Accommodation Coordinator, HR Labor & Employee Relations Division, by phone at 469-801-1728 or by email at . The IRS - Office of Chief Counsel provides reasonable accommodations to qualified applicants with disabilities on a case-by-case basis. You must contact us by 5:00 p.m. Eastern Standard Time on the announcement's closing date to request accommodation. If you are deaf, hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay services. To begin, click Apply to access the online application. You will need to be logged into your USAJOBS account to apply. If you do not have a USAJOBS account, you will need to create one before beginning the application. Follow the prompts to select your resume and/or other supporting documents to be included with your application package. You will have the opportunity to upload additional documents to include in your application before it is submitted. Your uploaded documents may take several hours to clear the virus scan process. After acknowledging you have reviewed your application package, complete the Include Personal Information section as you deem appropriate and click to continue with the application process. You will be taken to the online application which you must complete in order to apply for the position. Complete the online application, verify the required documentation is included with your application package, and submit the application. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete. It is your responsibility to verify that your application package (resume, supporting documents, and responses to the questionnaire) is complete, accurate, and submitted by the closing date. Uploaded documents may take up to one hour to clear the virus scan. Agency contact information Malva Trowser Phone Fax (855) 562-3827 Email Address Office of Chief Counsel, IRS Staffing and Classification Branch 1111 Constitution Ave, NW Washington, DC 20224 US Next steps To verify the status of your application, log into your USAJOBS account (https://my.usajobs.gov/Account/Login), all of your applications will appear on the Welcome screen. The Application Status will appear along with the date your application was last updated. For information on what each Application Status means, visit: . Fair & Transparent The Federal hiring process is set up to be fair and transparent. Please read the following guidance.