Office of Chief Counsel, IRS, the largest tax law firm in the country, is looking for enthusiastic individuals to join our team and gain valuable experience in a legal environment. Our mission is to serve America's taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. It is a great place to work with an excellent benefits package and family-friendly atmosphere.
This announcement is being used to fill positions within multiple Business Units in the Office of Chief Counsel. As a General Attorney (Tax) for the Associate Chief Counsel, you will perform the following principal duties within your assigned Business Unit and expertise:
- Draft published guidance, including regulations, revenue rulings, revenue procedures, etc.
- Provide written legal advice to taxpayers and field components of the IRS.
- Make recommendations regarding litigation; review briefs and other litigation-related documents.
The following are additional duties within assigned Business Units:Corporate:
Provides legal advice, litigation services and litigation support on matters involving corporate organizations, reorganizations, liquidations, spin-offs, transfers to controlled corporations, distributions to shareholders, debt vs. equity determinations, bankruptcies, and consolidated return issues affecting groups of affiliated corporations among other matters.Financial Institutions and Products:
Provides legal advice, litigation services and litigation support on tax matters involving financial institutions and the taxation of financial products to include banks, thrift institutions, insurance companies, regulated investment companies, real estate investment trusts, asset securitization arrangements, life insurance contracts, annuities, options, futures contracts, original issue discount obligations, hedging arrangements, and government entities issues including tax-exempt bonds and other types of innovative financial instruments and entities.Income Tax and Accounting:
Provides legal advice, litigation services and litigation support on tax matters involving recognition and timing of income and deductions by individuals and corporations, sales and exchanges, capital gains and losses, accounting methods and periods, depreciation and other cost recovery issues, installment sales, long-term contracts, inventories and alternative minimum tax.International:
Provides legal advice, technical guidance (including guidance published in the Federal Register and/or Internal Revenue Bulletin), and litigation support on matters involving the international provisions of the United States revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party. Participates in the Organization for Economic Cooperation and Development (OECD) as a delegate to the United States.Passthroughs and Special Industries:
Provides legal advice, litigation services and litigation support on tax matters involving income taxes of S corporations, partnerships (including limited liability companies), 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.
This is not an all-inclusive list. If selected at a lower grade level, you will have the opportunity to learn to perform the duties of the position and will receive training to help you grow in the position.
This is an open-continuous/standing register announcement that is open 07/10/2023 to 12/29/2023. Applicants will be referred to the selecting officials and referral lists issued as vacancies occur.
Cutoff for receipt of applications will be midnight EST on the date a vacancy has been determined. Applications received after that date, may be considered on future referral lists. Notifications will be sent to applicants when application has been referred or not referred. The announcement may close prior to 12/29/2023, if management has succeeded in filling all vacancies and has no further use for a standing register. RequirementsConditions 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) you must meet the qualification requirements listed below at the time of referral or by the closing of this announcement, whichever is first:Basic Requirements for General Attorney (Tax)
GS-12 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;
GS-13 Experience Requirements:
- 1 year of general professional legal experience
GS-14 Experience Requirements:
- 1 year of general professional legal experience; plus
- 1 year of professional legal tax experience
- 1 year of general professional legal experience; plus
- 2 year(s) of professional legal tax experience
Professional Legal Tax Experience is defined as legal work in one of following areas of tax expertise: Corporate; Financial Institutions and Products; Income Tax and Accounting; International; or Passthroughs and Special Industries. 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.
Tax Area Expertise may include, but not limited to the following experience:Corporate:
Experience working on the application of Federal Income Tax laws concerning Subchapter C and the consolidated return regulations to complex corporate transactional issues, including corporate organizations, reorganizations, liquidations, spin-offs, transfers to controlled corporations, distributions to shareholders, debt vs. equity determinations, bankruptcies, and consolidated return issues affecting groups of affiliated corporations among other matters.Financial Institutions and Products
: Tax matters involving financial institutions and financial products, including the taxation of banks, insurance companies, regulated investment companies, real estate investment trusts, asset securitization arrangements, life insurance contracts, annuities, notional principal contracts, options, forwards, futures, debt instruments (including original issue discount obligations and tax-advantaged bonds), hedging arrangements, and other types of innovative financial instruments and entities.Income Tax and Accounting:
Experience working on general tax accounting issues, such as: recognition and timing of income and deductions, sales and exchanges, capital gains and losses, accounting methods and periods, installment sales, long term contracts, and inventories, and assignments involving complex and difficult legal questions requiring extensive research, analysis, and evaluation.International:
Legal tax experience in U.S. international tax matters. Such experience should involve experience in providing regulatory and other technical guidance and legal advice on a variety of international tax issues pertaining to cross-border transactions and activities, such as taxation of inbound or outbound investment, including areas such as the TCJA provisions, subpart F, foreign tax credits, sourcing of income and deductions, income tax treaties, cross-border financial transactions, international corporate and partnership issues, transfer pricing, withholding, and exchange of information, in the context of planning, examination, and/or litigation, and assignments involving complex and difficult legal questions requiring extensive research, analysis, and evaluation.Passthroughs and Special Industries
: Taxation matters involving passthrough entities, including the income taxation of partnerships, S corporations, trusts, and their owners and beneficiaries, the classification of entities, the taxation of estates, gifts, and generation-skipping transfers, income tax credits, cooperative housing corporations, farmers' and other cooperatives, low-income housing credits, research and experimental expenditures, taxation concerning natural resources and energy production, certain homeowner associations, and certain excise tax issues.
Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience. Education Substitution:
An LL.M. degree in the field of this position (i.e. 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 a bargainingunit 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 1-year supervisory or managerial probationary 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)"