About the Agency
WHAT DOES A COMPETENT AUTHORITY (TAX TREATY) ANALYST DO? The position seeks a tax professional for the Treaty Assistance and Interpretation Team (TAIT) within the office of the Deputy Commissioner (International) and U.S. Competent Authority, under the direction of the Assistant Deputy Commissioner (International). Incumbent serves an expert in tax treaty interpretation and application with respect to United States tax treaties as well as tax information exchange agreements. The major responsibilities include providing authoritative advice and assistance on tax treaty matters (other than transfer pricing and allocation issues).
WHAT IS THE LARGE BUSINESS AND INTERNATIONAL (LB&I) DIVISION OF THE INTERNAL REVENUE SERVICE? The Large Business and International (LB&I) business unit provides service and enforcement activities to support tax compliance of businesses and related entities with assets of $10 million or more, as well as small U.S. businesses engaged in international, U.S. citizens abroad, and foreign persons and businesses with a U.S. tax requirement. As our name suggests, international tax administration is an important part of what we do in LB&I. As part of the LB&I team, you will be assigned to work in International. Regardless of where you serve, you will be supported by a variety of specialists (economists, engineers, field specialists and technical advisors) as you tackle the most complex tax issues.
2 Positions are located in Assistant Deputy Commissioner International in Washington, DC.
The anticipated start date is 07/14/2014. This announcement has been extended until 4/30/2014
WHERE CAN I FIND OUT MORE ABOUT OTHER IRS CAREERS? If you want to find out moreabout IRS careers, visit us on the web at ww.jobs.irs.gov
As a Competent Authority Analyst (Tax Treaty) you will:
- Receive and review taxpayer requests for assistance in obtaining relief from double taxation, or taxation otherwise inconsistent with the applicable treaty, including requests for relief under treaty provisions concerning residency, limitation on benefits, artists, athletes and entertainers, withholding, and all issues other than those involving transfer pricing and related allocation of business profits provisions.
- Perform a balanced and critical analysis of taxpayer and treaty-partner proposals and perform due diligence to ensure that the facts and circumstances of the taxpayer's case are sufficiently understood and known to arrive at a legally-supportable and wellreasoned determination.
- Evaluate, analyze, and develop the positions of the United States with respect to complex tax treaty interpretation and assistance issues and other international tax issues, with minimal direct supervision. Participate in the development of U.S. Competent Authority positions and presentations and, as needed, independently represents the U.S. Competent Authority at OECD and other non-governmental organizations concerned with international tax issues.
- Conduct independent research and analysis of tax, accounting, treaty, and economic issues and coordinate with IRS subject-matter experts, when necessary.
- Prepare positions and other memoranda for the U.S. Competent Authority, recommending a course of action based on analysis of the facts of the case, applicable tax law and treaty provisions, and the position of the foreign country.
- Negotiate with foreign tax officials on the disposition of individual cases in such a way that U.S. interests are pursued with due consideration of U.S. federal income tax law and the obligation of the United States to pursue relief from double taxation under its tax treaties. Draft detailed memoranda, position papers, and generally applicable and taxpayer specific agreements entered into with foreign governments known as "Mutual Agreements" and is responsible for preparing documents implementing the Mutual Agreement with the foreign country.
- Perform program analyst and staff assignments regarding non-case-related matters. Reviews Counsel-prepared material (e.g., regulations or revenue procedures) for accuracy and consistency in respect of tax treaty administration matters. Participate in and support Treasury-led teams negotiating tax treaties, representing the unique tax administration interests of the IRS and the U.S. Competent Authority. Participate in and contribute to the International Practice Networks (IPNs), particularly with respect to the core group that is developing and administering the Tax Treaty IPN.
- 25% or Greater
- Travel locally and/or overnight approximately 1 to 6 nights per month.