General Attorney(Tax) - Senior Counsel

Washington, D.C
Nov 25, 2022
Nov 29, 2022
Full Time

This position is located in the Office of Associate Chief Counsel, Passthroughs and Special Industries. The Senior Counsel serves as a legal expert on matters under the jurisdiction of the Office of the Associate Chief Counsel (Passthroughs and Special Industries) (PSI), acting as consultant to the Branch Chief, the Deputy Associate Chief Counsel, or the Associate Chief Counsel. PSI provides legal advice and litigation support services on tax matters involving passthrough entities, the classification of entities, passive activity losses, excise taxes, estate and gift taxes, oil and gas and other natural resources, at-risk rules, and tax credits to the Internal Revenue Service, the Office of Chief Counsel, the Department of Justice, Treasury, and where appropriate or required, to other government agencies and the public. As such, the incumbent must perform a variety of duties that may involve case or project work in which the incumbent is responsible for personally carrying out. This includes complex research, advisory, analysis, and review functions to handle and resolve specific cases or complicated issues. These cases and issues can require decision-making and review/signatory responsibility for final products or outcomes as delegated by the manager; and for program responsibilities in which the incumbent is responsible for assisting in efforts to improve the quality and efficiency of legal practices and services provided by PSI.

A General Attorney (Tax), Senior Counsel:
  • Serves as Senior Counsel with responsibility for personally handling, and performing technical review of, some of the office's most complex, important, or novel case/project assignments, particularly those with broad, or potentially controversial ramifications. Provides expert advice and litigation support services on the most complicated tax matters involving passthrough entities, the classification of entities, passive activity losses, excise taxes, estate and gift taxes, oil and gas and other natural resources, at­ risk rules, and tax credits to the Internal Revenue Service, the Office of Chief Counsel, the Department of Justice, Treasury, and where appropriate or required, to other government agencies and the public. As delegated by the manager, independently plans, develops and completes complex legal work products without review, and provides technical guidance and review of other staff work products. Ensures such products are technically complete and adhere to office policy, and exercises signatory authority on own and others' products in accordance with delegated authority. Applies a high level of sophisticated analysis and research to identify and assess approaches to make recommendations on behalf of the Office to program executives and managers. As appropriate, interacts with personnel from other Counsel offices, IRS, Treasury, other Federal agencies, and/or others on behalf of PSl to exchange information and coordinate actions in the handling and completion of assignments.
  • Serves as team leader on large-scale PSI guidance and publication projects that may include representatives from other Counsel Divisions or IRS offices. Directs and coordinates work of other team members, and oversees all related administrative and logistical matters.
  • In connection with the review of complex advisory opinions, private letter rulings, closing agreements, Chief Counsel Advice, technical advice, revenue rulings, revenue procedures, notices, announcements, briefs, defense letters, affirmative suit letters, settlement letters, and other technical materials for publication, develops procedural guidelines to assist PSI attorneys in the development of office products and issuances.
  • Researches complex issues and trends affecting PSI legal services and determines likely legal ramifications on PSI programs. Ensures that the legal or administrative consequences of potential actions to handle these issues are fully considered, and writes decision papers to determine Counsel's position on these matters. Decision papers can serve as future guidelines in the handling of these legal issues.
  • Serves as a primary reviewer on proposed legislation with potential impact on PSI programs, and prepares final comments/recommendations on behalf of the office. Identifies the need for and develops and drafts new procedures and regulations to implement new or amended legislation to insure that policies are consistent with the intent of the law and are administratively sound and economical in operation and to enable PSI to effectively meet its mission.
  • As designated by management, acts as a recognized legal resource specialist to other office staff for the purpose of providing substantive guidance and assistance to less senior attorneys to facilitate the development and completion of legal work assignments. When requested, assists in the identification of legal staff training needs, and in the development and delivery of such training.


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 General Attorney (Tax), Senior Counsel you must meet the qualification requirements listed below by the closing of this announcement:

Basic Requirements for General Attorney (Tax), Senior 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: Provides legal advice, litigation services and litigation support on tax matters involving income taxes of S corporations, partnerships, trusts, estates, gifts, generation-skipping transfers, certain excise taxes, income tax credits, cooperative housing corporations, farmers' and other cooperatives, low-income housing credit, research and expenditures, taxation concerning natural resources and energy production, and certain homeowner associations.

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-15).

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.

Time in Grade Requirement for GS-15: Applicants who have held a General Schedule (GS) position within the last 52 weeks must have 52 weeks of Federal service at the next lower grade or equivalent (GS-14).


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 aBargainingunit 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).
  • 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.
  • 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.