Attorney-Advisor (Tax) - Special Counsel

Washington, D.C
Oct 06, 2022
Oct 14, 2022
Full Time

This position is located in Washington, DC, in the Office of the Associate Chief Counsel (International). The Special Counsel acts as the personal, legal, and technical consultant to the Associate Chief Counsel (International) and the Deputies Associate Chief Counsel (International) on the most difficult, important, and complex field service, litigation, strategic program, technical guidance, and other matters arising in the administration of the Internal Revenue laws. The Special Counsel also works closely with the branches within International (which are comprised of groups of attorneys specializing in particular areas of international tax).

As a Attorney-Advisor (Tax) - Special Counsel, you will:
  • The Special Counsel advises the Associate and Deputies, as well as the Chief Counsel and Deputies Chief Counsel, in connection with technical guidance as well as the tax consequences of all cross- border transactions and activities; represents the IRS and the Treasury Department on sensitive, complex, and controversial issues related to this guidance and these transactions and activities; and researches and develops innovative recommendations regarding the position to be taken by the Office. If requested by the Associate or Deputies, the Special Counsel may function as an integral member of an International branch when a branch would benefit from the expertise.
  • The Special Counsel assists in the preparation and review of technical guidance, including with respect to drafting regulations, announcements, notices, and news releases, revenue rulings and revenue procedures; as well as coordinating legislative proposals or recommendations about legislation that particularly affects international activities. The Special Counsel operates 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.
  • The Special Counsel ensures 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. The Special Counsel renders 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 participates in the preparation of briefs and other materials in connection with U.S. Tax Court litigation involving international matters.
  • The Special Counsel prepares or reviews 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. The Special Counsel provides continuing support to ensure that LB&I operations are consistent with the full and effective implementation of all Chief Counsel objectives, policies, and procedures, including the development and monitoring of strategies and programs; and works with other key managers to form an effective management team responsive to the needs of all programs that LB&I supports.
  • The Special Counsel represents the Office as a guest speaker before national associations or professional groups, for the purpose of furthering, advancing, and explaining the position of the Office of Chief Counsel, the IRS, and the Treasury Department on matters of interest to professional associations or groups.
  • The Special Counsel performs such other professional legal duties as the Associate or Deputies may direct.


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


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 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 legal experience; plus
  • 3 year(s) of legal tax experience

Legal Tax Experience is defined as: Specialized knowledge and experience includes the following: In international and foreign tax matters, including multinational organizations with U.S. based personnel or activities. Experience includes areas such as multilateral tax treaties, advance pricing agreements, foreign tax credits, refund litigation, and other issues relating to international tax policy, legislation and litigation.

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).

Education Substitution: An LL.M. degree in the field of the position ( tax, GLS-related, or P&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 Department of Education Accreditation page .

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 anon-bargainingunit position.
  • We offer opportunities for telework.
  • We offer opportunities for flexible work schedules.
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
  • Must successfully complete a background investigation.
  • Complete a Declaration for Federal Employment to determine your suitability for Federal employment, at the time requested by the agency.
  • If you are a male applicant born after December 31, 1959, certify that you have registered with the Selective Service System or are exempt from having to do so.
  • Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
  • Go through a Personal Identity Verification (PIV) process that requires two forms of identification from the Form I-9 . Federal law requires verification of the identity and employment eligibility of all new hires in the U.S.
  • 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.