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. 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.
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This job is open to
- Internal to an agency
Current federal employees of this agency.
Clarification from the agency
Open to Office of Chief Counsel employees within the Associate Chief Counsel (International) only.
Duties
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.
Requirements
Conditions of Employment
- Refer to "Additional Information"
- Click "Print Preview" to review the entire announcement before applying.
- 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.
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: Branch 6 has jurisdiction over transfer pricing and related regimes and penalties, the deduction for foreign-derived intangible income, classification of certain digital content and cloud transactions, and special sourcing provisions under section 863 related to inventory sales, transportation income, space and ocean activities, and international communications, and provides specialized assistance to Treaty and Transfer Pricing Operations.
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).
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 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: Recognition of Foreign Qualifications | International Affairs Office (ed.gov) .
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 bargaining unit position.
- We offer opportunities for telework.
- We offer opportunities for flexible work schedules.
Conditions of Employment Continued: - Subject to a 1-year trial period (unless already completed).
- Subject to a 1-year supervisory or managerial probationary 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.
- Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
- Obtain and use a Government-issued charge card for business-related travel.
- File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on.
- Undergo an income tax verification.
- The employment of any candidate, including a current employee or a new hire, selected for this position may be conditional upon classification and/or audit of federal tax returns. This audit may include up to 2 years of returns.
- 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: - Noncriminal Justice Applicant's Privacy Rights , for those who undergo an FBI fingerprint-based criminal history record check for personnel vetting, which includes Rap Back,
- FD-258 Privacy Act Statement - FBI (this is the same statement used when your fingerprints are submitted as part of your background investigation), and
- SEAD-3-Reporting-U.pdf (dni.gov) , (applicable to those who hold a sensitive position or have eligibility for access to classified information)"
- 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. Opens in a new window Learn more about federal benefits .
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: All 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.
Bargaining Unit Chief Counsel employees will be given first consideration. To receive first consideration, Bargaining Unit Chief Counsel employees seeking reassignment must be on the Master First Consideration List (MFCL). In regard to this announcement, the MFCL is only for reassignments of employees currently occupying Bargaining Unit positions. If you are applying for a promotion, please apply to the announcement.
If you are a GS-14 applying for a promotion or you are a GS-15 reassignment (non-hardship), please apply to the announcement. In regard to this announcement, the MFCL is only for hardship reassignments of employees currently occupying GS-15 Senior Counsel positions. Current GS-15 Senior Counsel employees seeking reassignment due to a hardship will be given first consideration and must be on the Master First Consideration List.
- 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. Opens in a new window Learn more about federal benefits .
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
As a new or existing federal employee, you and your family may have access to a range of benefits. Your benefits depend on the type of position you have - whether you're a permanent, part-time, temporary or an intermittent employee. You may be eligible for the following benefits, however, check with your agency to make sure you're eligible under their policies.
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 resume tips .
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 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 memorandum of interest summarizing your interest in the position.
- A Supervisory Report for Non Supervisory Positions (Senior Counsel Only) (ERB Form 1-88a, Rev. 4-11) regarding your suitability for the position as completed by your current 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.
Employment Documentation: Submit a copy of your most recent SF-50, Notification of Personnel Action, which shows your current (or most recent) grade.
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.
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. - 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 01/02/2025 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: https://apply.usastaffing.gov/ViewQuestionnaire/12648531
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 Kimberly.F.Johnson@irscounsel.treas.gov . 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.
- Follow the prompts to select your resume and/or other supporting documents to be included with your application package. You will have the opportunity to upload additional documents to include in your application before it is submitted. Your uploaded documents may take several hours to clear the virus scan process.
- After acknowledging you have reviewed your application package, complete the Include Personal Information section as you deem appropriate and click to continue with the application process.
- You will be taken to the online application which you must complete in order to apply for the position. Complete the online application, verify the required documentation is included with your application package, and submit the application. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete.
- 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. Uploaded documents may take up to one hour to clear the virus scan.
- Additional information on how to complete the online application process and submit your online application may be found on the USA Staffing Applicant Resource Center .
Agency contact information
Malva Trowser
Phone 469-801-0076 Fax (855) 562-3827 Email malva.e.trowser@irscounsel.treas.gov
Address Office of Chief Counsel, IRS
Staffing and Classification Branch
1111 Constitution Ave, NW
Washington, DC 20224
US
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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: https://www.usajobs.gov/Help/how-to/application/status/ . - Fair and Transparent
The Federal hiring process is set up to be fair and transparent. Please read the following guidance. - Criminal history inquiries
- Equal Employment Opportunity (EEO) Policy
- Financial suitability
- New employee probationary period
- Privacy Act
- Reasonable accommodation policy
- Selective Service
- Signature and false statements
- Social security number request
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