Internal Revenue Service General Attorney (Tax) in Washington, District Of Columbia
Summary Office of Chief Counsel, IRS, the largest tax law firm in the country, is looking for enthusiastic individuals to join our team and gain valuable experience in a legal environment. Our mission is to serve America's 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. It isa great place to work with an excellent benefits package and family-friendly atmosphere. Responsibilities This announcement is being used to fill positions within multiple Business Units in the Office of Chief Counsel. As a GS-14 General Attorney (Tax) for theAssociate Chief Counsel, you will perform the following principal duties within your assigned Business Unit and expertise: Draft published guidance, including regulations, revenue rulings, revenue procedures, etc. Provide written legal advice to taxpayers and field components of the IRS. Make recommendations regarding litigation; review briefs and other litigation-related documents. The following are additionaldutieswithin assigned Business Units: Corporate: Provides legal advice, litigation services and litigation support on matters involving corporate organizations, reorganizations, liquidations, spin-offs, transfers to controlled corporations, distributions to shareholders, debt vs. equity determinations, bankruptcies, and consolidated return issues affecting groups of affiliated corporations among other matters. Employee Benefits, Exempt Organizations, and Employment Taxes: Provides legal advice, litigation services and litigation support on matters involving employee benefits including qualified retirement plans, IRAs, executive compensation arrangements, and health and welfare plans, exempt organizations, employment taxes, and certain issues related to federal, state, local and Indian tribal governments. Financial Institutions and Products: Provides legal advice, litigation services and litigation support on tax matters involving financial institutions and the taxation of financial products to include banks, thrift institutions, insurance companies, regulated investment companies, real estate investment trusts, asset securitization arrangements, life insurance contracts, annuities, options, futures contracts, original issue discount obligations, hedging arrangements, and government entities issues including tax-exempt bonds and other types of innovative financial instruments and entities. Income Tax and Accounting: Provides legal advice, litigation services and litigation support on tax matters involving recognition and timing of income and deductions by individuals and corporations, sales and exchanges, capital gains and losses, accounting methods and periods, depreciation and other cost recovery issues, installment sales, long-term contracts, inventories and alternative minimum tax. International: Provides legal advice, technical guidance (including guidance published in the Federal Register and/or Internal Revenue Bulletin), and litigation support on matters involving the international provisions of the United States revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party. Participates in the Organization for Economic Cooperation and Development (OECD) as a delegate to the United States. Passthroughs and Special Industries: Provides legal advice, litigation services and litigation support on tax matters involving income taxes of S corporations, partnerships (including limited liability companies), trusts, estates, gifts, generation-skipping transfers, certain excise taxes, income tax credits, cooperative housing corporations, farmers' and other cooperatives, low-income housing credit, research and expenditures, and certain homeowner associations. Procedure and Administration: Provides legal advice and litigation support services on tax matters involving the procedural aspects of filing returns and paying taxes; information reporting; assessment and collection of taxes (including interest and penalties); abating, crediting or refunding over-assessments or overpayments of tax; whistleblower matters; disclosure, Privacy and the Freedom of Information Act; bankruptcy practice and procedure; summonses and the gathering of information; ethics; the Administrative Procedure Act; Foreign Bank Account Reporting; user fees; and judicial practice and procedures. Please note this list of duties is not all inclusive. NOTE: (Closing Date Changed) This is an open-continuous announcement that is open January 26, 2021to August 31, 2021. Applicant will be referred to the selecting officialsand referral lists issuedas vacancies occur. Cutoff for receipt of applications will be midnight EST on the date a vacancy has been determined.Applications received after that date, may be considered on future referral lists. Notifications will be sent to applicants when application has been referred or not referred. The announcement may close prior to August 31, 2021, if management has succeeded in filling all vacancies and has no further use for a standing register. Applications may be updated and/or resubmitted to continue receiving consideration till the closing date of this announcement. Requirements Conditions of Employment Please refer to "Conditions of Employment". Click "Print Preview" to review the entire announcement before applying. CONDITIONS OF EMPLOYMENT: A one-yeartrial period is required. Must successfully complete a background investigation. 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, please 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. Go through a Personal Identity Verification (PIV) process that requires two forms of identification from the Form I-9. Federal law requires verification of the identity and employment eligibility of all new hires in the U.S. Obtain and use a Government-issued charge card for business-related travel. Sign a 3 year Tenure Commitment Letter 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 totwo years of returns. Because of its tax-related mission, the Office of Chief Counsel requires fingerprinting, tax verification, and a background security investigation as part of the pre-employment process. Qualifications You must meet the following requirements by the cut-off dates of this announcement: GS-14: Possess a J.D. andthree years of professional attorney experience - one year of general legal attorney experience plus two years of legal tax experience (comparable to the GS-13 level in the Federal service). OR Possess an LL.M. degreeandtwo years oflegal taxexperience (comparable to the GS-13 level in the Federal service). In addition,2 Yearsof Specialized experience is required in at leastone of the following areas of tax expertise: Corporate; Financial Institutions and Products; Income and Products; Income Tax and Accounting; International; Passthroughs and Special Industries; Proceduresand Administration;or Employee Benefits, Exempt Organizations, and Employment Taxes. Tax Area Expertise is defined as, but not limited to the following: Corporate: Experience working onthe application of Federal Income Tax laws concerning Subchapter C and the consolidated return regulations to complex corporate transactional issues. Financial Institutions and Products: Tax matters involving financial institutions; the taxation of financial products or transactions including deposits, debt instruments, options, forwards, futures, notional principal contracts, and other derivative financial products, virtual currency, or other financial transactions; the taxation of gain or loss on disposition of property; or cross-border aspects of financial institutions and financial products Income Tax and Accounting: Providing legal advice and litigation support on tax matters involving recognition and timing of income and deductions of individuals and corporations, sales and exchanges, capital gains and losses, accounting methods and periods, installment sales, long-term contracts, inventories and alternative minimum tax to the Internal Revenue Service, the Office of Chief Counsel, the Department of the Treasury, or to other government agencies and the public. International: Legal tax experience in U.S. international tax matters. Such experience includes taxation of inbound or outbound investment, including areas such as the TCJA provisions, income tax treaties, subpart F, foreign tax credits and sourcing of income and deductions, international corporate and partnership issues, cross-border financial transactions, transfer pricing, and withholding, in the context of planning, examination, and/or litigation, and assignments involving complex and difficult legal questions requiring extensive research, analysis, and evaluation. Passthroughs and Special Industries: Tax matters involving income taxes of S corporations, partnerships (including limited liability companies), trusts, estates, gifts, generation-skipping transfers, certain excise taxes, income tax credits, cooperative housing corporations, farmers' and other cooperatives, low-income housing credit, research and expenditures, and certain homeowner associations. Procedures and Administration: Experience with Federal Tax Practice and Procedure issues which include extensive research, analysis and evaluation of complex and difficult legal questions. Employee Benefits, Exempt Organizations, and Employment Taxes: Experience handling of sophisticated legal issues and interpretation and/or compliance work related to exempt organizations tax issue, employment taxes, Health and Welfare tax issues, Qualified Plans, or executive compensation Other qualifications for this position include: The J.D. and/or LL.M. must be from an ABA-accredited law school. Candidates must be admitted to practice law before the highest court of a state or territory of the United States; the District of Columbia; or the Commonwealth of Puerto Rico. One year of professional legal experience refers to full-time work after admittance to the bar. Part-time work is considered on a prorated basis. The professional legal experience may have been gained in either the public or private sector. To ensure full credit for your work experience, please indicate on your resume the dates of employment by month/year,as well as the number of hours worked per week. Education You must have graduated with a J.D. and/or LL.M. from an ABA-accredited law school. 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. If you are qualifying based on foreign education, you must submit proof of credibility of education as evaluated by a credentialing agency. Refer to the OPM instructions. Additional Information Other 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 and flexible work schedules.