The position is located in the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS).
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The International Transfer Pricing Specialist is an expert in the analysis and application of relevant law to significant international tax compliance issues relating to Internal Revenue Code (IRC) §482 and corresponding Treasury Regulations. The incumbent collaborates directly with IRS Examination Teams relating to the development of audit plans, fact gathering, and the preparation of position papers, including Forms 5701 (Notice of Proposed Adjustment). The incumbent participates as a technical expert in tax compliance examinations and provides expert advice that may impact tax policy and the International Examination Program as a whole. The incumbent may participate as a member of IRS teams, including but not limited to Practice Networks (PNs), and on other projects or assignments focused on specific international tax issues. The incumbent may coordinate or participate in a national tax compliance task force.
Assists Examination Teams in planning, directing, and coordinating the examination of international transfer-pricing issues. The incumbent serves on a consulting basis for other Examination and International Specialists, Counsel Attorneys, Appeals Officers, and Revenue Agents regarding the examination of transfer-pricing issues and transactions. The incumbent may also be assigned to work closely with IRS Examination Teams on multiple examinations simultaneously.
Collaborates and coordinates with Examination and International Specialists, Counsel Attorneys, Appeals Officers, and Revenue Agents to leverage and expand international issue expertise throughout the IRS, and to ensure consistent application and interpretation of international tax law. The incumbent regularly participates in groups focused on international issues including, but not limited to, PNs; and interacts regularly with personnel in the Advance Pricing and Competent Authority programs (APMA).
Participates in long-term projects involving the development of new auditing techniques, work practices, and training programs for Examination Specialists, Counsel Attorneys, Appeals Officers, and Revenue Agents. The incumbent may be assigned to develop and conduct training sessions and hold periodic meetings with IRS personnel at national and local office levels to review all matters relating to international transfer-pricing.
Performs research and analysis of tax issues involving economics, transfer pricing, and valuation related to specific taxpayers or across taxpayers and industries.
Provides feedback, technical expertise, and recommendations to IRS management and IRS Counsel on transfer-pricing issues. The International Transfer Pricing Specialist identifies and discusses any issues that require technical advice, field service advice, or industry-wide coordination procedures to be followed.
Meets with taxpayers, industry representatives, members of professional associations, and national tax administrators to explain IRC §482 transfer-pricing issues, and to seek alternate resolution opportunities. Also provides specialized assistance to other governmental agencies and national tax administrations regarding tax matters relating to transfer-pricing issues.
Coordinates, leads, or collaborates with the national analyses of tax issues involving significant international transfer-pricing transactions related to specific taxpayers or across taxpayer, industry, and international boundaries.
To ensure compliance with an applicable preliminary nationwide injunction, which may be supplemented, modified, or vacated, depending on the course of ongoing litigation, the Federal Government will take no action to implement/enforce the COVID-19 vaccination requirement pursuant to Executive Order 14043 on Requiring Coronavirus Disease 2019 Vaccination for Federal Employees. Federal agencies may request information regarding the vaccination status of selected applicants for the purposes of implementing other workplace safety protocols, such as protocols related to masking, physical distancing, testing, travel, and quarantine.
Must be a U.S. Citizen or National and provide proof of U.S. Citizenship. (Birth certificate showing birth in the U.S; Unexpired U.S. Passport; Certificate of Citizenship or Naturalization; or Report of Birth Abroad of a U.S. Citizen (Form FS-240))
Undergo a review of prior performance/conduct and an income tax verification. Refer to "Get Your Tax Record" at http://www.irs.gov/(https://www.irs.gov/individuals/get-transcript) to check the status of your account, balance owed, payment history, make a payment, or review answers to tax questions. If you are not in compliance, you will be determined unsuitable for employment with IRS.
Must successfully complete a background investigation, including a FBI criminal history record check (fingerprint check).
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. These documents must be unexpiredoriginal or certified copies.
Qualifications
Federal experience is not required. 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-timework 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.
You must meet the following requirements by the closing date of this announcement:
SPECIALIZED EXPERIENCE: Applicants must have one year of specialized experience at a level of difficulty and responsibility equivalent to the GS-13 level in the Federal Service. Examples of specialized experience include:
Experience with application of tax law to transfer pricing projects, transactions, and controversies, including application of the Internal Revenue Code, corresponding Treasury Regulations, tax treaties, Court decisions and the Organization for Economic Cooperation and Development (OECD) Guidelines related to transfer pricing between US and foreign related parties including transfers of tangible and intangible property, high value services, asset valuations, and risk allocation; Applying auditing techniques to multiple, interrelated transfer pricing issues as listed above on large corporate returns. Performing research and analysis of transfer pricing issues; conducting various kinds of audit steps verifying taxpayers' economic structure, business practices and functions; reviewing and analyzing economic, financial, operational and tax data to determine the existence of a potential transfer pricing issue; performing analyses to determine and/or evaluate tax reporting of intercompany transactions; providing technical advice concerning transfer pricing issues on cases; providing advice and recommendations to other examiners within issue networks during workshops and other knowledge sharing forums. Experience preparing and delivering written and oral communications to explain and defend the Government's position related to transfer pricing; holding conferences with taxpayers, their representatives and others to present and discuss transfer pricing positions and analysis; Experience serving, where necessary, as a qualified witness for the government in litigation cases. Experience assisting on competent authority cases or advance pricing agreements; correlative adjustments, set offs, or commensurate with income; and experience with treaty partners such an exchange of Information (EOI), Joint Audit, or International Compliance Assurance Program (ICAP).
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.
Note: If substituting Superior Academic Achievement (SAA) for experience at the GS-7 level, please note that grade-point averages are rounded to one decimal place. For example, 2.95 will round to 3.0 and 2.94 will round to 2.9. The Qualifications requirements above will reflect if SAA is accepted for this position and the online questionnaire will offer the option to select SAA as a qualifying response.
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: Education completed in foreign colleges or universities may be used to meet the requirements. You must show proof the education credentials have been deemed to be at least equivalent to that gained in conventional U.S. education program. It is your responsibility to provide such evidence when applying. Click here for Foreign Education Credentialing instructions.
Additional information
This is an open continuous announcement which allows applicants to apply through the closing date of the announcement 04/13/2023. The announcement will be used to fill an anticipated 10 vacancies. Selections may be made from certificates issued up to 12 months after the 1st cut-off date, 07/13/2022 listed in this announcement. Contingent upon funding and space requirements, one or more vacancies may be filled at the locations listed in this announcement as they become available. Applicants need to apply and/or update their applications by 11:59 pm ET at the close of each of the following cutoff and/or closing date 04/13/2023. This announcement may be amended to include additional cut-off dates within the 12-month period if needed, not later than 10 days prior to the additional cut-off date(s).
Subject to a 1-year probationary period (unless already completed).
Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
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.
The salary range indicated in this announcement reflects the minimum locality pay up to maximum locality pay for all duty locations listed. The range will be adjusted for selected duty location. General Schedule locality pay tables may be found under Salaries & Wages.
This is a bargaining unit position.
Tour of Duty: Monday - Friday 8:00 am- 4:30 PM
Alternative work schedule, staggered work hours or telework may be available.
May be eligible for telework based on IRS policy. If you are in a telework eligible position, you may be directed to temporarily telework on a full-time basis due to COVID 19. Employees must be within a 200-mile radius of their official assigned post-of-duty (POD) while in a telework status. Once normal operations resume, employees may be directed back to the office to perform the duties of their position. Telework eligibility does not guarantee telework; employees must meet and sustain IRS telework eligibility requirements and supervisor's approval to participate in the IRS Telework Program. As a reminder - If you are selected for a position, you are responsible for reporting to your designated POD (location) on the negotiated start date or as directed by management.
Please consider each location carefully when applying. If you are selected for a position at one of your location selections, that location will become your official post of duty.
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.
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: You will be assessed on the following competencies (knowledge, skills, abilities, and other characteristics):
Data Analysis
Influencing/ Negotiating
Interpersonal Skills
Legal, Government and Jurisprudence
Oral Communication
Planning and Evaluating
Tax Law and Practices
Workload Management
Writing
Category rating will be used to rank and select eligible candidates. If qualified, you will be assigned to one of two quality level categories, CAT A/B, CAT C depending on your responses to the online questions, regarding your experience, education, and training related to this position. 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. Candidates, if required to participate in a selection interview (telephonic and/or in person at the discretion of the Selecting Official in accordance with hiring practices), will be interviewed in quality group order. We will not reimburse costs related to the interview such as travel to and from the interview site.
Veterans' preference is applied after applicants are assessed. Preference-eligibles will be listed at the top of their assigned quality group and considered before non-preference-eligibles in that quality group. Qualified preference-eligibles with a compensable service-connected disability of 10% or more will be listed at the top of the highest quality group for this position. For scientific and professional positions Qualified preference-eligibles with a compensable service-connected disability of 10% or more will be listed at the top of the highest category for this position, except at the GS-09 and above.
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.
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.
The following documents are required and must be provided with your application. All application materials, including transcripts, must be in English.
Resume - Your resume MUST contain dates of employment (i.e., month/year to month/year or to present). To ensure you receive full credit for relevant experience, include the hours worked per week. We recommend that your resume not exceed 5 pages, only the first 5 pages will be reviewed to determine your eligibility/qualifications. If including Federal service experience, provide pay plan, series and grade, i.e. GS-0301-09. Your resume must NOT include photographs, inappropriate content, or personal information such as age, gender, religion, social security number. If your resume does not contain the required information specified, or contains prohibited information as listed above, your application will be determined incomplete, and you will not receive consideration for this position. (Cover letters are optional.) Please view Resume Tips.
Online Application - Questionnaire
Education - See Education Section above
Registration/License (if applicable) - active, current registration/license
Veterans' Preference (if applicable) - You MUST submit a copy of your DD-214 (Member 4 copy), or other official documentation from a branch of the Armed Forces or the Department of Veterans Affairs showing dates of service and type of discharge. If you are serving under active duty, provide certification from the Armed Forces that you will be discharged or released within 120 days from the date of certification. The certification must indicate your dates of service, rank and that you will be separated under honorable conditions. Submit an Application for 10-point Veteran Preference, SF-15, along with the required documentation listed on the back of the form if you are a 10-point preference eligible. For more information on veterans' preference view FedsHireVets.
Military Spouses (if applicable) - You MUST submit verification of the marriage to the service member (i.e., a marriage license or other legal documentation verifying marriage) AND:
a copy of your spouse's active military orders; OR
verification of your spouse's 100% service-connected disability (e.g., VA Letter and/or DD-214); OR
verification of the service member's death while on active duty (DD-1300/Death Certificate). You are not eligible if you were not married to the veteran at the time of death or have since remarried.
Career Transition Assistance Plan (CTAP) (if applicable) - You MUST submit the required documentation as outlined at: Career Transition Assistance Plan (CTAP). If you are an IRS CTAP eligible, you can apply for jobs within and outside the commuting area. If you are a Treasury CTAP eligible can apply for jobs within the commuting area.
Interagency Career Transition Assistance Plan (ICTAP) (if applicable) - If you are a displaced or surplus Federal employee, click Interchange Career Transition Assistance Plan (ICTAP) for eligibility and a detailed list of required documents.
Please note that if you do not provide all required information, as specified in this announcement, your application will be determined incomplete, and you will not be considered for this position (or may not receive the special consideration for which you may be eligible).
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 04/13/2023 and/or cut-off dates in 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 04/13/2023.
To begin the application process, click the "Apply Online" button.
You will be re-directed to USA STAFFING to complete your application process; answer the online questions and submit all required documents. (To submit supporting documents, import documents from USAJOBS to the appropriate document types. If the document you need was not imported from USAJOBS, you may upload it directly into this application. To protect your privacy, we suggest you first remove your SSN).
To complete, you must click the "Submit Application" button prior to 11:59 PM (ET) on 04/13/2023.
To update your application, including supporting documentation, at any time during the announcement open period, return to your USAJOBS account (https://my.usajobs.gov/Account/Login). There you will find a record of your application, the application status, and an option to Update Application. This option will no longer be available once the announcement has closed.
To verify the status of your application both during and after the announcement open period, log into your USAJOBS account: https://my.usajobs.gov/Account/Login . All of your applications will appear on the Welcome page. The application record in your USAJOBS account provides an Additional Application Information page that provides information regarding the documentation you submitted and any correspondence we have sent related to this application. 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/.
Large Business and International
1111 Constitution Ave NW
Washington, DC 20224
US
Next steps
Treasury believes in a working environment that supports inclusion; please view our reasonable accommodation policies and procedures at https://www.jobs.irs.gov/midcareer/reasonable-accommodation.html. We provide reasonable accommodation to applicants with disabilities on a case-by-case basis; contact us if you require this for any part of the application and hiring process.
Once your application package and online questionnaire is received you will receive an acknowledgement email. You are responsible for checking status updates and notifications in USAJOBS. Hard copy notifications will not be sent to you. 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. If your email mailbox is full or blocked (SPAM) 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.
The following documents are required and must be provided with your application. All application materials, including transcripts, must be in English.
Resume - Your resume MUST contain dates of employment (i.e., month/year to month/year or to present). To ensure you receive full credit for relevant experience, include the hours worked per week. We recommend that your resume not exceed 5 pages, only the first 5 pages will be reviewed to determine your eligibility/qualifications. If including Federal service experience, provide pay plan, series and grade, i.e. GS-0301-09. Your resume must NOT include photographs, inappropriate content, or personal information such as age, gender, religion, social security number. If your resume does not contain the required information specified, or contains prohibited information as listed above, your application will be determined incomplete, and you will not receive consideration for this position. (Cover letters are optional.) Please view Resume Tips.
Online Application - Questionnaire
Education - See Education Section above
Registration/License (if applicable) - active, current registration/license
Veterans' Preference (if applicable) - You MUST submit a copy of your DD-214 (Member 4 copy), or other official documentation from a branch of the Armed Forces or the Department of Veterans Affairs showing dates of service and type of discharge. If you are serving under active duty, provide certification from the Armed Forces that you will be discharged or released within 120 days from the date of certification. The certification must indicate your dates of service, rank and that you will be separated under honorable conditions. Submit an Application for 10-point Veteran Preference, SF-15, along with the required documentation listed on the back of the form if you are a 10-point preference eligible. For more information on veterans' preference view FedsHireVets.
Military Spouses (if applicable) - You MUST submit verification of the marriage to the service member (i.e., a marriage license or other legal documentation verifying marriage) AND:
a copy of your spouse's active military orders; OR
verification of your spouse's 100% service-connected disability (e.g., VA Letter and/or DD-214); OR
verification of the service member's death while on active duty (DD-1300/Death Certificate). You are not eligible if you were not married to the veteran at the time of death or have since remarried.
Career Transition Assistance Plan (CTAP) (if applicable) - You MUST submit the required documentation as outlined at: Career Transition Assistance Plan (CTAP). If you are an IRS CTAP eligible, you can apply for jobs within and outside the commuting area. If you are a Treasury CTAP eligible can apply for jobs within the commuting area.
Interagency Career Transition Assistance Plan (ICTAP) (if applicable) - If you are a displaced or surplus Federal employee, click Interchange Career Transition Assistance Plan (ICTAP) for eligibility and a detailed list of required documents.
Please note that if you do not provide all required information, as specified in this announcement, your application will be determined incomplete, and you will not be considered for this position (or may not receive the special consideration for which you may be eligible).
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 04/13/2023 and/or cut-off dates in 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 04/13/2023.
To begin the application process, click the "Apply Online" button.
You will be re-directed to USA STAFFING to complete your application process; answer the online questions and submit all required documents. (To submit supporting documents, import documents from USAJOBS to the appropriate document types. If the document you need was not imported from USAJOBS, you may upload it directly into this application. To protect your privacy, we suggest you first remove your SSN).
To complete, you must click the "Submit Application" button prior to 11:59 PM (ET) on 04/13/2023.
To update your application, including supporting documentation, at any time during the announcement open period, return to your USAJOBS account (https://my.usajobs.gov/Account/Login). There you will find a record of your application, the application status, and an option to Update Application. This option will no longer be available once the announcement has closed.
To verify the status of your application both during and after the announcement open period, log into your USAJOBS account: https://my.usajobs.gov/Account/Login . All of your applications will appear on the Welcome page. The application record in your USAJOBS account provides an Additional Application Information page that provides information regarding the documentation you submitted and any correspondence we have sent related to this application. 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/.
Large Business and International
1111 Constitution Ave NW
Washington, DC 20224
US
Next steps
Treasury believes in a working environment that supports inclusion; please view our reasonable accommodation policies and procedures at https://www.jobs.irs.gov/midcareer/reasonable-accommodation.html. We provide reasonable accommodation to applicants with disabilities on a case-by-case basis; contact us if you require this for any part of the application and hiring process.
Once your application package and online questionnaire is received you will receive an acknowledgement email. You are responsible for checking status updates and notifications in USAJOBS. Hard copy notifications will not be sent to you. 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. If your email mailbox is full or blocked (SPAM) 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.
