Internal Revenue Service
Attorney-Advisor (Tax) Special Counsel
Internal Revenue Service, Los Angeles, California, United States, 90079
Duties
The Special Counsel supports the Deputy Associate Chief Counsel (Controversy & Litigation) and the Associate Chief Counsel (International) in all matters involving controversy and litigation, including maintaining close working relationships with the other Chief Counsel Divisions, the Internal Revenue Service (IRS) Divisions, and the Department of Justice. International's objectives include advising government stakeholders in all matters involving international tax controversy and litigation, including against regulation challenges and issues of first impression under provisions of the Tax Cuts and Jobs Act, Inflation Reduction Act, and regulations under each, as well as important, newly arising issues under longstanding law, such as transfer pricing, treaty interpretation, and common law doctrines, and the application of the foregoing to aggressive tax planning. International provides technical guidance to the IRS, other Chief Counsel Divisions, and the DOJ to support the enforcement of tax laws involving cross-border transactions and activities. The Special Counsel works closely with the branches within International (which are comprised of groups of attorneys specializing in particular areas of international tax).As an Attorney-Advisor (Tax) Special Counsel, you will:Draft both legal and non-legal documents ranging from tax advocacy designed for legal practitioners to non-technical/educational materials targeted for more general use. Provide oral and written advice applying the tax laws related to cross-border transactions and activities, including the international provisions of the U.S. revenue laws, and bilateral and multilateral tax treaties and agreements to which the United States is a party. Exercise decision-making skills, including in case or project management. Analyze and interpret complex tax legislation, regulations, and policy matters that impact international tax policies and guidance.Operate as a critical link between subject matter experts in the International office and other Counsel offices, as well as personnel in Appeals and Examination, with respect to the preparation of technical guidance, international field service, litigation, and strategic programs.Ensure that controversies stemming from cross-border transactions and activities are developed and handled consistently with the correct interpretation of international provisions of the U.S. 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.Render legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning international issues under examination in the audit of returns or in the consideration of claims for refunds or in respect of matters of treaty interpretation; and participate in the preparation of briefs and other materials in connection with U.S. Tax Court litigation involving international matters.Prepare or review recommendations concerning the defense, settlement, concession, or appeal of refund suits pending in international cases in the U.S. District Courts or the U.S. Court of Federal Claims; and works with the Department of Justice in connection with preparation of briefs and positions and strategy taken in international appellate litigation.This is not an all-inclusive list.Requirements
Conditions of Employment
Must be a U.S. Citizen or NationalQualifications
In order to qualify, you must meet the education and/or experience requirements detailed below by the closing date of this announcement. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.Basic Requirements for Attorney-Advisor (Tax) Special Counsel:Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; ANDApplicants 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 professional legal experience from any area of expertise; plus3 years of professional legal tax experience.Professional Legal Tax Experience is defined as: Litigation and controversy experience involving the taxation of cross-border transactions and activities in proceedings before IRS Exam, IRS Independent Office of Appeals, and/or in the U.S. Tax Court, the U.S. Court of Federal Claims, the United States District Courts, and/or the U.S. Courts of Appeals. 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) may be substituted for the one year of the general legal experience listed above.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.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 a non-bargaining unit position.We offer opportunities for telework.We offer opportunities for flexible work schedules.How to Apply
The following instructions outline our application process. You must complete this application process and submit any required documents by 11:59 p.m. Eastern Time (ET) on 10/17/2024. To begin, click
Apply
to access the online application. You will need to be logged into your USAJOBS account to apply.Agency contact information:Malva TrowserPhone: (855) 562-3827Address: Office of Chief Counsel, IRS, Staffing and Classification Branch, 1111 Constitution Ave, NW, Washington, DC 20224, US
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The Special Counsel supports the Deputy Associate Chief Counsel (Controversy & Litigation) and the Associate Chief Counsel (International) in all matters involving controversy and litigation, including maintaining close working relationships with the other Chief Counsel Divisions, the Internal Revenue Service (IRS) Divisions, and the Department of Justice. International's objectives include advising government stakeholders in all matters involving international tax controversy and litigation, including against regulation challenges and issues of first impression under provisions of the Tax Cuts and Jobs Act, Inflation Reduction Act, and regulations under each, as well as important, newly arising issues under longstanding law, such as transfer pricing, treaty interpretation, and common law doctrines, and the application of the foregoing to aggressive tax planning. International provides technical guidance to the IRS, other Chief Counsel Divisions, and the DOJ to support the enforcement of tax laws involving cross-border transactions and activities. The Special Counsel works closely with the branches within International (which are comprised of groups of attorneys specializing in particular areas of international tax).As an Attorney-Advisor (Tax) Special Counsel, you will:Draft both legal and non-legal documents ranging from tax advocacy designed for legal practitioners to non-technical/educational materials targeted for more general use. Provide oral and written advice applying the tax laws related to cross-border transactions and activities, including the international provisions of the U.S. revenue laws, and bilateral and multilateral tax treaties and agreements to which the United States is a party. Exercise decision-making skills, including in case or project management. Analyze and interpret complex tax legislation, regulations, and policy matters that impact international tax policies and guidance.Operate as a critical link between subject matter experts in the International office and other Counsel offices, as well as personnel in Appeals and Examination, with respect to the preparation of technical guidance, international field service, litigation, and strategic programs.Ensure that controversies stemming from cross-border transactions and activities are developed and handled consistently with the correct interpretation of international provisions of the U.S. 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.Render legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning international issues under examination in the audit of returns or in the consideration of claims for refunds or in respect of matters of treaty interpretation; and participate in the preparation of briefs and other materials in connection with U.S. Tax Court litigation involving international matters.Prepare or review recommendations concerning the defense, settlement, concession, or appeal of refund suits pending in international cases in the U.S. District Courts or the U.S. Court of Federal Claims; and works with the Department of Justice in connection with preparation of briefs and positions and strategy taken in international appellate litigation.This is not an all-inclusive list.Requirements
Conditions of Employment
Must be a U.S. Citizen or NationalQualifications
In order to qualify, you must meet the education and/or experience requirements detailed below by the closing date of this announcement. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.Basic Requirements for Attorney-Advisor (Tax) Special Counsel:Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; ANDApplicants 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 professional legal experience from any area of expertise; plus3 years of professional legal tax experience.Professional Legal Tax Experience is defined as: Litigation and controversy experience involving the taxation of cross-border transactions and activities in proceedings before IRS Exam, IRS Independent Office of Appeals, and/or in the U.S. Tax Court, the U.S. Court of Federal Claims, the United States District Courts, and/or the U.S. Courts of Appeals. 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) may be substituted for the one year of the general legal experience listed above.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.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 a non-bargaining unit position.We offer opportunities for telework.We offer opportunities for flexible work schedules.How to Apply
The following instructions outline our application process. You must complete this application process and submit any required documents by 11:59 p.m. Eastern Time (ET) on 10/17/2024. To begin, click
Apply
to access the online application. You will need to be logged into your USAJOBS account to apply.Agency contact information:Malva TrowserPhone: (855) 562-3827Address: Office of Chief Counsel, IRS, Staffing and Classification Branch, 1111 Constitution Ave, NW, Washington, DC 20224, US
#J-18808-Ljbffr