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Attorney Advisor (Tax), Senior Technical Reviewer (International)

Employer
USAJobs
Location
Washington, D.C
Closing date
Jan 19, 2021
Duties

Summary

The 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 Internal Revenue Service. It's a great place to work and a family-friendly atmosphere.

Learn more about this agency

Responsibilities

This position is located in the office of the Associate Chief Counsel (International, Branch 1). The Senior Technical Reviewer servers as a technical expert with respect to the tax areas relating to the functions of the assigned Branch. In addition, the STR is responsible for the assignment and review of the cases for some of the attorneys within the Branch; and, as assigned, may perform other administrative/management tasks within the Branch. The Senior Technical Reviewer in this position functions as an Assistant to the Branch Chief.

As a Senior Technical Reviewer the incumbent of this position:

The incumbent of this position serves as a Senior Technical Reviewer in Branch 1 of the Office of the Associate Chief Counsel (International), where he/she acts as legal and technical consultant to the Branch Chief, Deputy Associate Chief Counsel, Associate Chief Counsel (International), and, as assigned, to other officials in the Office of Chief Counsel on some of the most difficult, important, and complex professional legal matters concerned with the work of Branch 1, or which may affect the work of other Branches of the office, or other components of the Office of Chief Counsel. Such matters usually arise in connection with (a) technical advice to all field functions, (b) actions on decisions, (c) briefs, (d) unusual technical problems handled by the Branch, (e) publication program, (f) letter rulings, (g) treaties, (h) regulations, (i) legislation, and (j) certain designated substantive tax matters affecting international tax transactions. These matters involve detailed and extensive research on complicated legal problems and the development of recommendations as to the positions to be taken by the Branch and the Office. The principal subject matter areas of the branch includes jurisdiction over discrete issues involving income tax treaties, cross border employment issues (including pensions, stock options and social security issues), inbound taxation of foreign corporations (sections 864, 882 and 884), the residence and taxation of nonresident aliens, hybrid entities in the treaty context, the taxation and reporting rules for foreign trusts and estates, special rules for individuals who expatriate, transportation income and the foreign insurance excise tax.

Incumbent considers all questions which have broad, legal ramifications and renders appropriate decisions. In consultation with the Branch Chief, the incumbent is responsible for the assignment of selected cases and projects to the attorneys and specialist within the Branch and for review of the work products. As designated, the Senior Technical Reviewer serves as Branch Chief in the absence of that official, and performs other professional tasks as assigned.

Travel Required

Occasional travel - 5% or greater

Supervisory status
Yes

Promotion Potential
15

Requirements

Conditions of Employment

  • Please refer to " Conditions of Employment".
  • Click "Print Preview" to review the entire announcement before applying.
  • Applications will be accepted on-line via Career Connector.
  • If unable to apply on-line please contact Careerconnetorhelp@do.treas.gov
  • Public Trust Background Investigation required.


Other Information
  • Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
  • Must prepare an annual OGE 450, Confidential Financial Disclosure Report.
  • Subject to a 1-year trial 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.
  • 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.
  • 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.
  • Undergo an income tax verification.
  • Candidates must be admitted to practice law before the highest court of a state or territory of the United States; the District of Columbia; or the Commonwealth of Puerto Rico and be an active member by the closing date of the announcement.

Because of its tax-related mission, the Office of Chief Counsel requires fingerprinting, tax verification, and a background security investigation as part of the pre-employment process.

Qualifications

You must meet the following requirements by the closing date of this announcement:

To qualify for this position at the GS-15 grade level, you must have one year of specialized experience, equivalent in scope and effect to the GS-14 level.

Specialized experience: Thorough and comprehensive professional knowledge of Internal Revenue and Federal tax laws and regulations, and decisions applicable thereto, particularly as they relate to foreign and international tax laws and transactions. You must possess specific substantive knowledge and experience over discrete issues with respect to transfer pricing and related regimes and penalties, e-commerce, the section 250 deduction for foreign derived intangible income and global intangible low-taxed income and certain sourcing provisions, and familiarity with the APMA Program and Treaty and Transfer Pricing Operations.
  • The J.D. and/or the LL.M. must be from an ABA-accredited law school.
  • Candidates must be admitted to practice law before the highest court of a state or territory of the United States; the District of Columbia; or the Commonwealth of Puerto Rico.
  • One year of professional legal experience refers to full-time work after admittance to the bar. Part-time work is considered on a prorated basis.
  • Experience may have been gained in the public sector, private sector, or through Volunteer Service .
  • To ensure full credit for your work experience, please indicate on your resume the dates of employment by month/year, as well as number of hours worked per week.
  • GS-15: You must have been at the GS-14 level for 52 weeks. (time-in-grade requirement).
  • 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

Applicants must possess a J.D. and have one year of general legal experience plus three years of professional legal tax experience. An LL.M. degree in the field of the position (tax) may be substituted for one year of general legal experience listed above.

Specialized experience may have been gained while employed in a professional legal position in the Federal, state, or local government, the private sector including law firms, or nongovernmental organizations.

Additional information

  • We may select from this announcement or any other source to fill one or more vacancies.
  • This is a non-bargaining unit position.
  • We offer opportunities for telework.
  • We offer opportunities for flexible work schedules.


How You Will Be Evaluated

You will be evaluated for this job based on how well you meet the qualifications above.

Your application includes your resume and responses to the online questions and required supporting documents. Please be sure that your resume includes detailed information to support your qualifications for this position; failure to provide sufficient evidence in your resume will result in a "not qualified" determination.

Applicants will be considered based on their overall background as it relates to the position to be filled. All application materials and interviews, if conducted, will be used in the final evaluation and selection process.

If you meet the eligibility requirements, the Executive Resources Branch will assess your overall specialized knowledge and experience as it relates to the position to be filled, compare it to the other applicants' knowledge and experience and determine the candidate best qualified for the position. The board may or may not conduct interviews. You will be notified of the outcome.

Your application will be rated and ranked among others, based on your responses to the online questions, regarding your experience, training, performance appraisals and awards relevant to the duties of this position. Your rating may be lowered, if your responses to the online questions are not supported by the experience described in your application.

Referral: If you are among the top qualified candidates, your application may be referred to a selecting official for consideration. You may be required to participate in a selection interview.
To preview questions please click here .

Background checks and security clearance

Security clearance
Other

Drug test required
No

Required Documents

All applicants must submit the following documents: 1) Memorandum of Interest summarizing your interest in the position. 2) Resume detailing your relevant qualifications and specialized knowledge and experience. 3) A copy of your most recent official performance appraisal, or a progress review. 4) A Supervisory Report (ERB Form 1-88 Revised 07/2020) regarding your suitability for the position as completed by your current or most recent supervisor. You are responsible for notifying your supervisor that this report must be received no later than five workdays after the closing date of this announcement.

A complete application includes (1) a resume, (2) vacancy question responses, and (3) submission of any required documents. Please note that if you do not provide all required information, as specified in this announcement, you may not be considered for this position (or may not receive the special consideration for which you may be eligible).

All applicants are required to submit a resume either by creating one in USAJOBS or uploading one of their own choosing. We suggest that you preview the online questions, as you may need to customize your resume to ensure that it supports your responses to these questions. Please view resume tips .

Documentation Relating to Your Federal Employment

- Submit a copy of your SF-50, Notification of Personnel Action, which shows your current (or most recent) grade and competitive service status. (The "position occupied" block on the SF-50 should show a "1" or "2" and your "tenure" block should show a "1" or "2".)

- Indicate on your application the highest permanent grade you have held. If this grade is different from your current grade, submit a copy of an additional SF-50 showing this grade.

- Submit a copy of your most recent, signed, completed annual performance appraisal which includes the final rating. If the performance appraisal is not dated within the last 12 months or if you have not received a performance appraisal, please explain why in your application.

If you are relying on your education to meet qualification requirements:

Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from schools accredited by accrediting institutions recognized by the U.S. Department of Education .

Failure to provide all of the required information as stated in this vacancy announcement may result in an ineligible rating or may affect the overall rating.

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