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.
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Summary
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.
WHAT DOES A COMPETENT AUTHORITY ANALYST (APMA TEAM LEADER) DO? This position seeks tax professionals who will primarily perform the duties of an Advance Pricing and Mutual Agreement (APMA) Team Leader within the office of the Deputy Commissioner (International) and U.S. Competent Authority, under the Director of Transfer Pricing Operations. Incumbent possess substantial skill in the area of international tax provisions of the Internal Revenue Code relating to transfer pricing with advanced knowledge of relevant provisions in U.S. income tax treaties (e.g., Articles 7, 9 and 25), the Organization for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines, and foreign transfer pricing rules. The major responsibilities include leading teams of IRS professionals in the analysis and development of advance pricing agreements and the resolution of double tax cases arising from transfer pricing adjustments.
As a Competent Authority Analyst (APMA) you will:
Receive requests for competent authority consideration and/or APA submissions.
Review requests to ensure compliance with applicable procedural guidelines. Take necessary action to perfect requests.
Assist field revenue agents and other IRS technicians (attorneys, economists, and international examiners) to further develop facts/issues in cases. May secure additional information directly from taxpayer or treaty partner.
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, appropriate tax law and treaty, and the position of the foreign country.
Participate in or lead development of Bilateral Advance Pricing Agreements (APA), including preparing and negotiating the U.S. position, providing advice to both taxpayers and other IRS personnel concerning competent authority implications i.e., Mutual Agreement. Also, coordinates with appropriate IRS personnel to insure the review of APA Annual Reports to determine taxpayer compliance with previously executed agreements.
Negotiate with foreign Competent Authority representatives when the foreign official does not accept U.S. position on particular issues. Determine and recommend reasonable offers that will still protect U.S. interest. Assigned to a specific country as coordinator, specializing in specific country issues, and planning negotiation agenda. Responsible for preparing documents implementing the Mutual Agreement with the foreign country(ies).
Perform program analyst and staff assignments regarding non-case related matters. Review Counsel-prepared material (e.g., regulations or revenue procedures) for accuracy and consistency in respect of tax treaty administration matters.
Advise field agents and other IRS and Treasury personnel on competent authority issues.
Participate in Treasury-led teams negotiating tax treaties.
Speak before external and internal groups regarding competent authority procedures and tax treaty technical issues, e.g., in training classes and professional organizations, such as, the American Bar Association.
WHERE CAN I FIND OUT MORE ABOUT OTHER IRS CAREERS? If you want to find out more about IRS careers, visit us on the web at www.jobs.irs.gov
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Must be a U.S. Citizen or National
IRS Employees with Career or Career Conditional Appointments.
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Qualifications
You must meet the following requirements by the closing date of this announcement.
GS-14 LEVEL: You must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-13 grade level in the Federal service. Specialized experience for this position includes: demonstrating experience in methods and techniques pertaining to the interpretation and application of U.S. transfer pricing regulations, and to analyze and provide assistance to taxpayers requesting relief from double taxation related to transfer pricing adjustments; experience with U.S. transfer pricing regulations and the OECD Transfer Pricing Guidelines; experience in applying IRS Revenue Procedures covering requests for relief and the prevention of double taxation and other policies and procedural guidelines relating to competent authority matters; and experience with the Internal Revenue Code and regulations pertaining to transfer pricing to analyze and provide assistance to taxpayers requesting relief from double taxation.
-The experience may have been gained in the public sector, private sector or Volunteer Service. 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.
In addition to the above requirements, you must meet the following, if applicable: You must have been at the GS-13 level for 52 weeks (time-in-grade requirement).
Additional information
15 Positions are located in the Large Business and International Division (LB&I), Transfer Pricing Program, Advance Pricing and Mutual Agreement Program (APMA),and will be filled in any of the following locations: 999 N Capitol St NE, Washington, DC (DC0221), 26 Federal Plaza, New York, NY (NY0282), 230 S. Dearborn Street, Chicago, IL (IL0236), 450 Golden Gate Ave, San Francisco, CA (CA0154), 55 South Market Street, San Jose, CA (CA6116), 300 North Los Angeles St, Los Angeles, CA (CA0150), 24000 Avila Road, Laguna Niguel, CA (CA0521)
We may select from this announcement or any other source to fill one or more vacancies.
This is a bargainingunit position.
Alternative work schedule, staggered work hours or telework may be available.
Tour of Duty: Monday - Friday 8:00 a.m. - 4:30 p.m.
Must meet IRS telework eligibility requirements.
If you are an IRS/Treasury employee eligible for consideration under the Career Transition Assistance Plan (CTAP), you must submit proof of eligibility by 11:59 PM ET on the closing date of this announcement. If you have any questions concerning your eligibility, please refer back to the CTAP Documentation link in the vacancy under How You Will Be Evaluated.
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.
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 windowLearn more about federal benefits.
As a current employee, you know the great benefits we offer. Should you have any questions about benefits, please contact the Employee Resource Center (ERC) at 1-866-743-5748 option #1 for ERC.
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.
Your application includes your resume, responses to the online questions, and required supporting documents. Please be sure that your resume includes detailed information to support your qualifications for this position; failure to provide sufficient evidence in your resume may result in a “not qualified” determination. Rating: Your application will be evaluated on the CJEs of the position to be filled per the National Agreement Article 13. Your application will also be rated and ranked among others, based on your responses to the online questions, regarding your experience, education, training, performance appraisals and awards relevant to the duties of this position. IRS employees may obtain most recent awards listing at https://persinfo.web.irs.gov/ Your rating may be lowered, if your responses to the online questions are not supported by the education and/or experience described in your application. Referral: If you are among the top qualified candidates, your application may be referred to a selecting official for consideration. 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.If you are a displaced or surplus Treasury employee eligible for the Career Transition Assistance Plan (CTAP), you must receive a score of 80 or better to be rated as well qualified to receive special selection priority.
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 windowLearn more about federal benefits.
As a current employee, you know the great benefits we offer. Should you have any questions about benefits, please contact the Employee Resource Center (ERC) at 1-866-743-5748 option #1 for ERC.
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.
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 will 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.) Cover Letters 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 Resume Tips
Career Transition Assistance Plan (CTAP) DOCUMENTATION: If you are a displaced or surplus Treasury employee, click CTAP for eligibility and a detailed list of required documents. IRS CTAP eligibles can apply for jobs within and outside the commuting area. IRS Reassignment Preference Program (RPP): You must meet the requirements in your RPP notice. Submit a copy of your RPP Notice along with a copy of your most recent annual performance appraisal. Your performance appraisal must have a fully successful or higher overall rating.
PERFORMANCE APPRAISAL/AWARDS: Submit a copy of your most recent completed performance appraisal. IRS employees: If a revalidated appraisal is used for merit promotion, the supervisor must prepare a narrative for each critical job element that does not have a narrative describing the performance in the appraisal period covered by the rating. Note: If you are a manager or management official, your most recent annual performance appraisal must be used for the overall rating identified. EDUCATION DOCUMENTATION: If you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. If the position has specific education requirements and you are currently (or have previously been) in the Federal job series to be filled, there is no need to submit a transcript or equivalent at this time. 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. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. Refer to the OPM instructions.
If you are relying on your education to meet qualification requirements:
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.
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 the closing date of this announcement. We are available to assist you during business hours (normally 8:00 a.m. - 4:00 p.m. ET, Monday - Friday). If applying online poses a hardship, please contact us by noon ET on the announcement's closing date.
Treasury believes in a working environment that supports inclusion; please view our reasonable accommodation policies and procedures at https://jobs.irs.gov/seasonal/reasonable-accommodation.html. We will provide reasonable accommodation to applicants with disabilities on a case-by-case basis. Please contact us at sbseintapps@irs.gov if you require this for any part of the application and hiring process.
To begin, either click the “Create a New Account” button and follow the prompts to register or if you previously registered, click the "Apply Online" button and follow the prompts.
You will be re-directed to Treasury’s CareerConnector system to complete your application process; answer the online questions, and submit all required documents. (To submit supporting documents, click one of the available options; Upload; Fax; or Reuse existing documents. To protect your privacy, we suggest you first remove your SSN). Also, go to “My Account” to view and update your information, as necessary.
To complete, you must click the “Finish” button located at the bottom of the “Application Review” page.
To verify your application is complete, log into your USAJOBS account, select the Application Status link and then select the more information link for this position. The Details page will display the status of your application, the documentation received.
To return to an incomplete application, log into your USAJOBS account and click Update Application in the vacancy announcement. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete.
INTERNAL REVENUE SERVICE
2970 Market St
Philadelphia, Pennsylvania 19104
United States
Next steps
You may check the status of your application for this position at any time by logging onto the USAJOBS “My Account” tab and clicking on “Application Status.” For a more detailed update of your application status, you may click on “more information.”
Please notify us if your contact information changes after the closing date of the announcement. Also, note that if you provide an email address that is inaccurate or if your mailbox is full or blocked (e.g., spam-blocker), you may not receive important communication that could affect your consideration for this position.
The Federal hiring process is set up to be fair and transparent. Please read the following guidance.
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 will 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.) Cover Letters 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 Resume Tips
Career Transition Assistance Plan (CTAP) DOCUMENTATION: If you are a displaced or surplus Treasury employee, click CTAP for eligibility and a detailed list of required documents. IRS CTAP eligibles can apply for jobs within and outside the commuting area. IRS Reassignment Preference Program (RPP): You must meet the requirements in your RPP notice. Submit a copy of your RPP Notice along with a copy of your most recent annual performance appraisal. Your performance appraisal must have a fully successful or higher overall rating.
PERFORMANCE APPRAISAL/AWARDS: Submit a copy of your most recent completed performance appraisal. IRS employees: If a revalidated appraisal is used for merit promotion, the supervisor must prepare a narrative for each critical job element that does not have a narrative describing the performance in the appraisal period covered by the rating. Note: If you are a manager or management official, your most recent annual performance appraisal must be used for the overall rating identified. EDUCATION DOCUMENTATION: If you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. If the position has specific education requirements and you are currently (or have previously been) in the Federal job series to be filled, there is no need to submit a transcript or equivalent at this time. 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. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. Refer to the OPM instructions.
If you are relying on your education to meet qualification requirements:
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.
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 the closing date of this announcement. We are available to assist you during business hours (normally 8:00 a.m. - 4:00 p.m. ET, Monday - Friday). If applying online poses a hardship, please contact us by noon ET on the announcement's closing date.
Treasury believes in a working environment that supports inclusion; please view our reasonable accommodation policies and procedures at https://jobs.irs.gov/seasonal/reasonable-accommodation.html. We will provide reasonable accommodation to applicants with disabilities on a case-by-case basis. Please contact us at sbseintapps@irs.gov if you require this for any part of the application and hiring process.
To begin, either click the “Create a New Account” button and follow the prompts to register or if you previously registered, click the "Apply Online" button and follow the prompts.
You will be re-directed to Treasury’s CareerConnector system to complete your application process; answer the online questions, and submit all required documents. (To submit supporting documents, click one of the available options; Upload; Fax; or Reuse existing documents. To protect your privacy, we suggest you first remove your SSN). Also, go to “My Account” to view and update your information, as necessary.
To complete, you must click the “Finish” button located at the bottom of the “Application Review” page.
To verify your application is complete, log into your USAJOBS account, select the Application Status link and then select the more information link for this position. The Details page will display the status of your application, the documentation received.
To return to an incomplete application, log into your USAJOBS account and click Update Application in the vacancy announcement. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete.
INTERNAL REVENUE SERVICE
2970 Market St
Philadelphia, Pennsylvania 19104
United States
Next steps
You may check the status of your application for this position at any time by logging onto the USAJOBS “My Account” tab and clicking on “Application Status.” For a more detailed update of your application status, you may click on “more information.”
Please notify us if your contact information changes after the closing date of the announcement. Also, note that if you provide an email address that is inaccurate or if your mailbox is full or blocked (e.g., spam-blocker), you may not receive important communication that could affect your consideration for this position.
Fair and transparent
The Federal hiring process is set up to be fair and transparent. Please read the following guidance.
