Attorney Advisor (Tax), Special Counsel (International)

Washington, D.C
Mar 07, 2021
Mar 13, 2021
Full Time


The Office of Chief Counsel of the 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


This position is located in Washington, DC, the Office of the Associate Chief Counsel (International). The Special Counsel acts as the personal, legal and technical consultant to the Associate Chief Counsel (International) Deputies Associate Chief Counsel (International), on the most difficult, important and complex field service, litigation, strategic program, technical guidance or other matters arising in the administration of the Internal Revenue laws.

    • The Special Counsel operates as a critical link between subject matter experts in the International office, as well as other Counsel personnel, Appeals, and Examination with respect to international field service, litigation, strategic program, and technical guidance. The Special Counsel assists in identifying, developing, and coordinating issues presented in the Tax Court, refund litigation, summons enforcement, , and appellate cases; assists in the development of technical tax guidance, performs special assignments, and represents the Office in the regulation and revenue ruling review process; and renders advice on emerging issues, non-docketed significant matters, and strategic programs.
    • The Special Counsel ensures that controversies stemming from transactions and activities crossing the borders of the United States are developed and handled consistently with correct interpretation of international provisions of the United States revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party, and all foreign revenue laws that pertain to or affect tax matters in the United States.
    • The Special Counsel advises the Associate and Deputies on matters relating to the tax consequences of all transactions and activities that cross the borders of the United States. Represents the IRS and the Treasury Department on sensitive, extremely complex, and controversial issues related to these transactions and activities. Performs exhaustive and detailed research on complicated legal problems with broad ramifications, and develops and prepares innovative recommendations as to the position to be taken by the Office. As assigned, acts in an advisory capacity to the Commissioner of Internal Revenue Service, the Chief Counsel and Deputies Chief Counsel, and other top IRS, Counsel, and Treasury officials, advising them of possible and new courses of action and the consequences of controversial, complex, or unique international tax problems.
    • The Special Counsel assists in formulating and conducting programs and policies with respect to litigation of international issues in the Tax Court, and, together with the Division Counsel, determining which cases should be tried, settled, or conceded. Assures IRS-wide consistency of approach in international tax litigation; consults with personnel in the Division Counsel as to the defense or settlement of international cases pending in U.S. Tax Court (including the preparation and approval of Chief Counsel decisions) and, together with the Division Counsel, reviews and coordinates pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S. Tax Court litigation involving international matters.
    • Recommends whether to acquiesce in adverse decisions and orders in such cases and suits and makes recommendations to the Department of Justice regarding appeals, offers in compromise, or settlement in such cases or suits pending on appeal. Directly prepares and/or reviews recommendations concerning defense, settlement, or concession, with respect to refund suits pending in international cases in the U.S. District Courts or the Court of Federal Claims, as well as suit authorizations, including authorization to counterclaim or pursue third-party complaints, in those same courts. Works closely with the Department of Justice, as well as members of staff of the General Counsel and Commissioner of Internal Revenue when appropriate, to coordinate international appellate litigation.
    • Serves as the personal representative of the Associate and Deputies in the substantive review of technical guidance. Advises on matters of statutory interpretation (while coordinating with counterparts in Treasury's Office of Tax Policy, to implement appropriate policy) and the procedural and administrative burdens implicit in positions to be taken in published guidance, including working closely with those drafting revenue rulings, revenue procedures, announcements, and news releases, or coordinating legislative proposals or recommendations about legislation that particularly affects international activities, some potentially nationwide.

Travel Required

Occasional travel - 5% or greater

Supervisory status

Promotion Potential


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
  • Public Trust-Background Investigation required

  • 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).
  • 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.
  • If selected, you will be required to submit an original Certificate of Good Standing from your State Bar.

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.


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: You must possess the following specialized experience which is in, or directly related to, the work of the position to be filled. Specialized knowledge and experience includes the following: In international and foreign tax matters, including multinational organizations with U.S. based personnel or activities. Experience includes areas such as multilateral tax treaties, advance pricing agreements, foreign tax credits, refund litigation, and other issues relating to international tax policy, legislation and litigation.
  • 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 legal experience plus three years of professional legal tax 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 .
  • 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.


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.

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 .

If you are qualifying based on foreign education, you must submit proof of credibility of education as evaluated by a credentialing agency. Refer to the OPM instructions.

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.

The salary range indicated in this vacancy includes base pay only. Salary will be set with respect to the location of the position.

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. We will not reimburse costs related to the interview such as travel to and from the interview site.
To preview questions please click here .

Background checks and security clearance

Security clearance

Drug test required

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) Current Chief Counsel Employees Only a Supervisory Report (ERB Form 1-88, Rev 4/2011) 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. To receive full credit for relevant experience, please list the month/year and number of hours worked for experience listed on your resume. 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 .

VETERANS' PREFERENCE DOCUMENTATION: There is no formal rating system for applying veterans' preference to attorney appointments in the excepted service; however, the Office of Chief Counsel considers veterans' preference eligibility as a positive factor in attorney hiring. If you are claiming veterans' preference, you must submit a copy of your Certificate of Release or Discharge From Active Duty, DD-214 (Member 4 copy), or other official documentation from a branch of the Armed Forces or the Department of Veterans Affairs showing dates of service and type of discharge. Ten-point preference eligibles must also submit an Application for 10-point Veteran Preference, SF-15 , along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference view FedsHireVets .

CURRENT AND FORMER FEDERAL EMPLOYEES - 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.

Similar jobs