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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.
- Refer to "Additional Information"
- Click "Print Preview" to review the entire announcement before applying.
- Must be a U.S. Citizen or National
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.
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: .
- 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.
- 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:
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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.
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
- 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 Supervisory or Management Positions (ERB Form 1-88, Rev 7/2020) 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 .
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.
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 06/19/2024 and/or cut-off dates in this announcement. We are available to assist you during business hours (normally 7:30 a.m. to 4:00 p.m. 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 Keona Hill (EEO Director/Reasonable Accommodation Coordinator) by phone at 202-317-5739 or by email at . The IRS - Office of Chief Counsel provides reasonable accommodation to applicants with disabilities on a case-by-case basis. You must contact us by 5:00 p.m. Eastern 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. Counsel's EEO Office is not the point of contact for questions about the vacancy announcement.
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.
Fax
(855) 562-3827
Email
Staffing and Classification Branch
1111 Constitution Ave, NW
Washington, DC 20224
US
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: .
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