Attorney-Adviser (Tax) - Special Counsel - International

Summary

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.

To learn more, click the links below :

Summary

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.

To learn more, click the links below :

Overview

Accepting applications

Open & closing dates

09 / 10 / 2025 to 09 / 26 / 2025

Salary

$146,481 to - $195,200 per year

Pay scale & grade

GS 15

Locations

3 vacancies in the following locations :

Birmingham, AL

Phoenix, AZ

Laguna Niguel Office

Lake Forest, CA

Los Angeles, CA

Show more fewer locations (44)

Sacramento, CA

San Diego, CA

San Francisco, CA

San Jose, CA

Thousand Oaks, CA

Denver, CO

East Hartford, CT

Washington, DC

Jacksonville, FL

Miami, FL

Plantation, FL

Saint Petersburg, FL

Atlanta, GA

Honolulu, HI

Chicago, IL

Indianapolis, IN

Louisville, KY

New Orleans, LA

Boston, MA

Baltimore, MD

Detroit, MI

Saint Paul, MN

Kansas City, MO

Saint Louis, MO

Greensboro, NC

Newark, NJ

Las Vegas, NV

Buffalo, NY

Manhattan Office

New York, NY

Long Island Office

Westbury, NY

Cincinnati, OH

Cleveland, OH

Oklahoma City, OK

Portland, OR

Philadelphia, PA

Pittsburgh, PA

Nashville, TN

Austin, TX

Dallas Office

Farmers Branch, TX

Houston, TX

Salt Lake City, UT

Richmond, VA

Seattle, WA

Milwaukee, WI

Remote job

No

Telework eligible

Yes-as determined by the agency policy.

Travel Required

Occasional travel - You may be expected to travel for this position.

Relocation expenses reimbursed

No

Appointment type

Permanent

Work schedule

Full-time

Service

Excepted

Promotion potential

15

Job family (Series)

Supervisory status

No

Security clearance

Drug test

No

Position sensitivity and risk

Trust determination process

Financial disclosure

Bargaining unit status

Announcement number

CCMT-25-12795545-ATTY

Control number

845518000

This job is open to

Clarification from the agency

U.S. Citizens and U.S. Nationals; no prior Federal experience is required.

Duties

The Special Counsel serves as the legal and technical consultant to the Associate and Deputy Associate Chief Counsels (International) (INTL), on the most difficult, important and complex matters. INTL's responsibilities include legal issues arising out of 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; 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 taxation of foreign governments and international organizations and their employees), U.S. taxation relating to U.S. territories, 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; international information exchange and summons enforcement; conflict of laws and the application of income tax treaties and international agreements.

As an Attorney-Adviser (Tax) - Special Counsel, your duties will include the following :

• Operate as a critical link between subject matter experts in INTL 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.
• 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.
• Ensure that controversies stemming from cross-border transactions and activities are handled consistently with the 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.
• 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 work 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.

Announcement amended to include trial period requirements. See Conditions of Employment.

Requirements

Conditions of employment

Qualifications

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.

To qualify for this position of Attorney-Adviser (Tax) - Special Counsel, you must meet the qualification requirements listed below by the closing of this announcement :

Basic Requirements for Attorney-Adviser (Tax) - Special Counsel :

GS-15 Experience Requirements :

Professional Legal Tax Experience is defined as performing legal research and / or legal guidance in federal tax controversy, federal tax litigation, or federal tax consulting. 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 (e.g., 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 .

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 :

Additional information

Conditions of Employment Continued :

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 :

Expand Hide additional information

Candidates should be committed to improving the efficiency of the Federal government, passionate about the ideals of our American republic, and committed to upholding the rule of law and the United States Constitution.

Benefits

A career with the U.S. government provides employees with a comprehensive benefits package. As a federal employee, you and your family will have access to a range of benefits that are designed to make your federal career very rewarding. .

Eligibility for benefits depends on the type of position you hold and whether your position is full-time, part-time or intermittent. Contact the hiring agency for more information on the specific benefits offered.

How you will be evaluated

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

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

Referral : Professional Order will be used to refer and select eligible candidates. Veterans' preference is applied after applicants are assessed. Preference eligibles will be listed at the top of the certificate in alphabetical order and considered before non-preference eligibles. All other candidates will be listed in alphabetical order. If you are among the top qualified candidates, 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.

Benefits

A career with the U.S. government provides employees with a comprehensive benefits package. As a federal employee, you and your family will have access to a range of benefits that are designed to make your federal career very rewarding. .

Eligibility for benefits depends on the type of position you hold and whether your position is full-time, part-time or intermittent. Contact the hiring agency for more information on the specific benefits offered.

Required documents

Required Documents

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. (Cover letters are optional.) 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 .

In addition, applicants are required to submit :

Current Chief Counsel Employees are also required to submit :

Education Documentation : 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. See "Education" for more details.

Certificate of Good Standing : A certified original copy of your certificate of good standing from your State Bar will be required if you are selected.

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 , along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference, view .

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

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.

How to Apply

The following instructions outline our application process. You must complete this application process and submit any required documents by 11 : 59 PM Eastern Time (ET) on 09 / 26 / 2025 and / or cut-off dates in this announcement. We are available to assist you during business hours (normally 7 : 30 AM to 4 : 00 PM ET, Monday - Friday). To preview the Application Questionnaire, please click the following link :

If you require a reasonable accommodation for a disability or medical condition during any part of the application and hiring process, please contact Kimberly Johnson, Reasonable Accommodation Coordinator, HR Labor & Employee Relations Division, by phone at 469-801-1728 or by email at . The IRS - Office of Chief Counsel provides reasonable accommodations to qualified applicants with disabilities on a case-by-case basis. You must contact us by 5 : 00 p.m. Eastern Standard Time on the announcement's closing date to request accommodation. If you are deaf, hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay services.

To begin, click Apply to access the online application. You will need to be logged into your USAJOBS account to apply. If you do not have a USAJOBS account, you will need to create one before beginning the application.

Agency contact information

Malva Trowser

Phone

Fax

(855) 562-3827

Email

Address

Office of Chief Counsel, IRS

Staffing and Classification Branch

1111 Constitution Ave, NW

Washington, DC 20224

US

Next steps

To verify the status of your application, log into your USAJOBS account (https : / / my.usajobs.gov / Account / Login), all of your applications will appear on the Welcome screen. The Application Status will appear along with the date your application was last updated. For information on what each Application Status means, visit : .

Fair and transparent

The Federal hiring process is set up to be fair and transparent. Please read the following guidance.

Required Documents

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. (Cover letters are optional.) 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 .

In addition, applicants are required to submit :

Current Chief Counsel Employees are also required to submit :

Education Documentation : 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. See "Education" for more details.

Certificate of Good Standing : A certified original copy of your certificate of good standing from your State Bar will be required if you are selected.

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 , along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference, view .

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

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.

How to Apply

The following instructions outline our application process. You must complete this application process and submit any required documents by 11 : 59 PM Eastern Time (ET) on 09 / 26 / 2025 and / or cut-off dates in this announcement. We are available to assist you during business hours (normally 7 : 30 AM to 4 : 00 PM ET, Monday - Friday). To preview the Application Questionnaire, please click the following link :

If you require a reasonable accommodation for a disability or medical condition during any part of the application and hiring process, please contact Kimberly Johnson, Reasonable Accommodation Coordinator, HR Labor & Employee Relations Division, by phone at 469-801-1728 or by email at . The IRS - Office of Chief Counsel provides reasonable accommodations to qualified applicants with disabilities on a case-by-case basis. You must contact us by 5 : 00 p.m. Eastern Standard Time on the announcement's closing date to request accommodation. If you are deaf, hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay services.

To begin, click Apply to access the online application. You will need to be logged into your USAJOBS account to apply. If you do not have a USAJOBS account, you will need to create one before beginning the application.

Expand Hide how to apply

Agency contact information

Malva Trowser

Phone

Fax

(855) 562-3827

Email

Address

Office of Chief Counsel, IRS

Staffing and Classification Branch

1111 Constitution Ave, NW

Washington, DC 20224

US

Next steps

To verify the status of your application, log into your USAJOBS account (https : / / my.usajobs.gov / Account / Login), all of your applications will appear on the Welcome screen. The Application Status will appear along with the date your application was last updated. For information on what each Application Status means, visit : .

Expand Hide next steps

Fair and transparent

The Federal hiring process is set up to be fair and transparent. Please read the following guidance.

Additional locations

Sacramento, CA

San Diego, CA

San Francisco, CA

San Jose, CA

Thousand Oaks, CA

Denver, CO

East Hartford, CT

Washington, DC

Jacksonville, FL

Miami, FL

Plantation, FL

Saint Petersburg, FL

Atlanta, GA

Honolulu, HI

Chicago, IL

Indianapolis, IN

Louisville, KY

New Orleans, LA

Boston, MA

Baltimore, MD

Detroit, MI

Saint Paul, MN

Kansas City, MO

Saint Louis, MO

Greensboro, NC

Newark, NJ

Las Vegas, NV

Buffalo, NY

Manhattan Office

New York, NY

Long Island Office

Westbury, NY

Cincinnati, OH

Cleveland, OH

Oklahoma City, OK

Portland, OR

Philadelphia, PA

Pittsburgh, PA

Nashville, TN

Austin, TX

Dallas Office

Farmers Branch, TX

Houston, TX

Salt Lake City, UT

Richmond, VA

Seattle, WA

Milwaukee, WI