General Attorney (Tax) - Senior Technical Reviewer

Employer
USAJobs
Location
Washington, D.C
Posted
Nov 27, 2022
Closes
Dec 01, 2022
Hours
Full Time
Duties

This position is located in Washington, D.C., in the office of the Associate Chief Counsel (International). The Senior Technical Reviewer (STR) serves as a technical expert with respect to the tax areas relating to the functions of the Branch within International to which the attorney will be assigned. In addition, the STR is responsible for the assignment and review of the cases for some of the attorneys within the Branch; and may perform other administrative/management tasks. The STR functions as an Assistant to the Branch Chief. The principal subject matter areas will depend on the Branch, and could include one or more of the following:
  • the taxation of U.S. persons with foreign activities (foreign tax credits; taxation of income earned through direct or passive investments, controlled and non-controlled foreign corporations, passive foreign investment companies, unincorporated branch operations and foreign partnerships or trusts; foreign currency translation; foreign earned income; and information reporting obligations);
  • the taxation of foreign persons with U.S. activities (effectively connected income, branch profits tax, determination of U.S. residence and consequences of expatriation, withholding of tax on U.S. source income, FATCA, the taxation of foreign governments and international organizations and their employees); and
  • Taxation relating to U.S. territories, and laws relating to cross-border activities of both domestic and foreign persons (transfer pricing; entity classification; cross-border reorganizations; the source of income and allocation of deductions; taxation of financial products and income from international financial services and insurance activities; foreign currency transactions; taxation of income from shipping, space and ocean activities, international communications, and electronic commerce; international information exchange and summons enforcement; and application of income tax treaties and international agreements).
As a General Attorney (Tax) - Senior Technical Reviewer, you will:
  • Act as a legal and technical consultant to the Branch Chief, the Deputies and 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.
  • 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, 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 policies and developing 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. 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 regard, 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), 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 and 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. 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.
  • Perform other duties as assigned by management.


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

Legal Tax Experience is defined as one or more of the following areas, depending on the Branch: the taxation of U.S. persons with foreign activities (foreign tax credits; taxation of income earned through direct or passive investments, controlled and non-controlled foreign corporations, passive foreign investment companies, unincorporated branch operations and foreign partnerships or trusts; foreign currency translation; foreign earned income; and information reporting obligations), the taxation of foreign persons with U.S. activities (effectively connected income, branch profits tax, determination of U.S. residence and consequences of expatriation, withholding of tax on U.S. source income, the Foreign Account Tax Compliance Act (FATCA), the taxation of foreign governments and international organizations and their employees), U.S. taxation relating to U.S. territories and possessions, and laws relating to cross-border activities of both domestic and foreign persons (transfer pricing; entity classification; cross-border reorganizations; the source of income and allocation of deductions; taxation of financial products and income from international financial services and insurance activities; foreign currency transactions; taxation of income from shipping, space and ocean activities, international communications, and electronic commerce; international information exchange and summons enforcement; conflict of laws and the application of income tax treaties and international agreements).

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 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 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: http://www.ed.gov/about/offices/list/ous/international/usnei/us/edlite-visitus-forrecog.html .

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 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.