The Senior Counsel serves as a legal expert on matters under the jurisdiction of the Office of the Associate Chief Counsel (Corporate) (CORP), acting as consultant to the Branch Chief, the Deputy Associate Chief Counsel, or the Associate Chief Counsel. CORP provides legal advice and litigation support services on tax matters primarily involving subchapter C and the Consolidated return regulations. The subject matter includes corporate organizations, reorganizations, liquidations, spin-offs, transfers to controlled corporations, debt vs. equity determinations, bankruptcies, and issues affecting affiliated groups of corporations that file consolidated returns. The incumbent must perform a variety of duties that he or she is personally responsible for carrying out. The work 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. The incumbent is also responsible for assisting in efforts to improve the quality and efficiency of legal practices and services provided by CORP.
As a General Attorney (Tax) Senior Counsel, you will:
RequirementsConditions of Employment
- Serve as team leader on large-scale CORP guidance and publication projects that may involve representatives from other Counsel Divisions, IRS offices, and Treasury Office of Tax Policy. Direct and coordinate work of other team members. Oversee administrative and logistical matters related to these projects.
- Serve in connection with the review of Private Letter Rulings, Revenue Rulings, Chief Counsel Advice Memoranda, Technical Advice Memoranda, regulations and other forms of published guidance, develop procedural guidelines to assist CORP attorneys.
- Research complex issues and trends affecting CORP legal services and determine likely legal ramifications on CORP and other Counsel programs. Ensure that the legal or administrative consequences of potential actions to handle these issues are fully considered and write decision papers to determine Counsel's position on these matters. Decision papers can serve as future guidelines in the handling of these issues.
- Serve as a primary reviewer on proposed legislation with potential impact on CORP programs, and prepare final comments/recommendations on behalf of the Office. Identify the need for, develop and draft new procedures and regulations to implement new or amended legislation to ensure that policies are consistent with the intent of the law and are administratively sound and economical in operation.
- As designated by management, act 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, assist in the identification of legal staff training needs, and in the development and delivery of such training.
- Serve as Senior Counsel with responsibility for personally 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. Provide expert advice and litigation support services on the most complicated corporate tax matters. As delegated by the manager, independently plan, develop and complete complex legal work products without review, and provide technical guidance and review of work products of other staff members. Ensure such products are technically complete and adhere to office policy and exercise signatory authority on his or her own and others' products in accordance with delegated authority. Apply 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, interact with personnel from other Counsel offices, IRS, Treasury, other Federal agencies, and/or others on behalf of CORP to exchange information or coordinate actions in the handling and completion of assignments.
- Refer to "Additional Information"
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- 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:
GS-15 Experience Requirements:
- 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.
- 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: Transaction planning or tax controversy work, in cases involving business and corporate reorganization and corporation-shareholder issues, redemptions, liquidations, spin-offs, transfers to controlled corporations, corporate bankruptcies, and consolidated returns; OR Judicial or agency experience with cases involving business and corporate reorganization and corporation-shareholder issues, redemptions, liquidations, spin-offs, transfers to controlled corporations, corporate bankruptcies, and consolidated returns; OR Thorough and comprehensive knowledge of Internal Revenue and Federal tax laws and regulations, and decisions applicable thereto, particularly as they relate to business and corporate reorganization and corporation-shareholder issues, redemptions, liquidations, spin-offs, transfers to controlled corporations, corporate bankruptcies, and consolidated returns.
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, 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.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
Conditions of Employment Continued:
- 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.
- Subject to a 1-year trial period (unless already completed).
- Subject to a Tenure Commitment of up to 3 years.
- 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.
- 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:
- Noncriminal Justice Applicant's Privacy Rights , for those who undergo an FBI fingerprint-based criminal history record check for personnel vetting, which includes Rap Back,
- FD-258 Privacy Act Statement - FBI (this is the same statement used when your fingerprints are submitted as part of your background investigation), and
- SEAD-3-Reporting-U.pdf (dni.gov) , (applicable to those who hold a sensitive position or have eligibility for access to classified information)