General Attorney (Tax) - Senior Counsel Branch 4

Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve 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. Please click "Learn more about this agency" to find out more about Chief Counsel's various offices, to view some of the workplace attributes that Chief Counsel's workforce rates most favorably, and to hear from employees themselves. 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. The Senior Counsel serves as a legal expert on matters under the jurisdiction of the Office of the Associate Chief Counsel (International) (INTL), acting as consultant to the Branch Chiefs and other branch managers, the Deputy Associate Chief Counsel, and the Associate Chief Counsel. INTL develops guidance and provides legal advice and litigation support services on matters involving the taxation of U.S. persons with foreign activities (foreign tax credits; taxation of income earned through direct or passive investments, controlled and non-controlled foreign corporations, passive foreign investment companies, unincorporated branch operations and foreign partnerships or trusts; foreign currency translation; foreign earned income; and information reporting obligations), the taxation of foreign persons with U.S. activities (effectively connected income, branch profits tax, determination of U.S. residence and consequences of expatriation, withholding of tax on U.S. source income, the Foreign Account Tax Compliance Act (FATCA), the taxation of foreign governments and international organizations and their employees), U.S. taxation relating to U.S. territories and possessions, and laws relating to cross-border activities of both domestic and foreign persons (transfer pricing; entity classification; cross-border reorganizations; the source of income and allocation of deductions; taxation of financial products and income from international financial services and insurance activities; foreign currency transactions; taxation of income from shipping, space and ocean activities, international communications, and electronic commerce; international information exchange and summons enforcement; conflict of laws and the application of income tax treaties and international agreements.As a General Attorney (Tax) - Senior Counsel, you will:

• Serve as Senior Counsel with responsibility for personally handling, and 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. As delegated by the manager, independently plan, develops, and completes complex legal work products without review, and provides technical guidance and review of other staff work products.
• Serve as team leader on large-scale INTL guidance and publication projects that may include representatives from other Counsel Divisions or IRS offices. Directs and coordinates work of other team members and oversees all related administrative and logistical matters.
• In connection with the review of Chief Counsel Advice, general legal advice, technical advice memoranda, Private Letter Rulings, defense letters, settlement recommendations, appeal recommendations, closing agreements, prefiling agreements, advance pricing agreements, competent authority agreements, and similar documents, develop procedural guidelines to assist INTL attorneys in the development of office products and issuances.
• Research complex issues and trends affecting INTL legal services and determine likely legal ramifications on INTL 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 legal issues.
• Serve as a primary reviewer on proposed legislation with potential impact on INTL programs and prepare final comments/recommendations on behalf of the office. Identify the need for and 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 and to enable INTL to effectively meet its mission.

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.

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:

• 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-15 Experience Requirements:

• 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: Experience and expertise in tax laws relating to cross-border activities of both domestic and foreign persons (entity classification; cross-border reorganizations; repatriation; FIRPTA). Relevant code sections include sections 245A, 367, 864(c)(8), 897, 959/961, 1248, 1446, 1503(d), 6038B, and 7874.

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.

Time in Grade Requirement for GS-15: Applicants who have held a General Schedule (GS) position within the last 52 weeks must have 52 weeks of Federal service at the next lower grade or equivalent (GS-14).