The Special Counsel supports the Deputy Associate Chief Counsel (Controversy & Litigation) and the Associate Chief Counsel (International) ("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:
- 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.
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.
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 the 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.
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.
- The salary range indicated in this announcement covers multiple locality areas. Your salary will be adjusted based on the post of duty for which you are selected.
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).
- Subject to a Tenure Commitment of up to 3 years.
- 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.
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).
- 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.
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. We are available to assist you during business hours (normally 7:30 AM to 4:00 PM.ET, Monday - Friday).
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