Attorney-Advisor (Tax) Special Counsel

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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 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 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.

RequirementsConditions of Employment

Must be a U.S. Citizen or National

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.

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; 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 : 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).

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.

Required Documents

A complete application includes :

• A resume
• Vacancy question responses
• Submission of any required documents

In addition, applicants are required to submit :

• An unofficial or official transcript(s) for your J.D. degree or LL.M. degree (an official transcript is required if you are selected)
• An 8-10 page legal writing sample
• A memorandum of interest summarizing your interest in the position

Current Chief Counsel Employees are also required to submit :

• A copy of your most recent, signed, completed annual performance appraisal which includes the final rating. If it is not dated within the last 12 months or if you have not received a performance appraisal, please explain why in your application.
• A Supervisory Report for Non-Supervisory Positions (Senior Counsel Only) regarding your suitability for the position as completed by your current supervisor.

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 and / or cut-off dates in this announcement.

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.

It is your responsibility to verify that your application package (resume, supporting documents, and responses to the questionnaire) is complete, accurate, and submitted by the closing date.

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