The position is located in the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS).
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.
STANDARD POSITION DESCRIPTIONS (SPD):
PD97643
Visit the IRS SPD Library to access the position descriptions.
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.
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-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.
You must meet the following requirements by the closing date of this announcement:
SPECIALIZED EXPERIENCE: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:
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).
AND
MEET TIME IN GRADE (TIG) REQUIREMENT: For positions above the GS-05, applicants must meet applicable time-in-grade requirements to be considered eligible. One year (52 weeks) at the next lower grade level is required to meet the time-in-grade requirements for the grade you are applying for.
AND
TIME AFTER COMPETITIVE APPOINTMENT: By the closing date (or if this is an open continuous announcement, by the cut-off date) specified in this job announcement, current civilian employees must have completed at least 90 days of federal civilian service since their latest non-temporary appointment from a competitive referral certificate, known as time after competitive appointment. For this requirement, a competitive appointment is one where you applied to and were appointed from an announcement open to "All US Citizens".
A copy of your transcripts or equivalent documentation is required for positions with an education requirement, or if you are qualifying based on education or a combination of education and experience. An official transcript will be required if you are selected. If the position has specific education requirements and you currently hold, or have previously held, a position in the same job series with the IRS, there is no need to submit a transcript or equivalent at this time. Applicants are encouraged, but are not required, to submit an SF-50 documenting experience in a specific series.
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 dates to be considered: 07/13/2022, 10/13/22, 01/13/23, closing: 04/13/23. 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).
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.
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.
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 Critical Job Elements (CJE) of the position to be filled, in accordance with Article 13 of the IRS/NTEU National Agreement. Your application will also be rated and ranked among others, based on your responses to the online questions/assessment. Your experience, education, training, prior performance, and awards, relevant to the position being filled, will be considered throughout the hiring process. IRS employees may obtain most recent awards listing at https://persinfo.web.irs.gov/.
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 (telephonic and/or in person at the discretion of the Selecting Official in accordance with hiring polices). 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 Federal employee eligible for 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.
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. 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 responses
Education - See Education Section above
Performance Appraisal/Awards - Submit a copy of your most recent completed performance appraisal. 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.
Registration/License (if applicable) - active, current registration/license
IRS Reassignment Preference Program (RPP)(if applicable) - 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.
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.
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).
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 USASTAFFING 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 will provide reasonable accommodation to applicants with disabilities on a case-by-case basis; please 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.
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.
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. 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 responses
Education - See Education Section above
Performance Appraisal/Awards - Submit a copy of your most recent completed performance appraisal. 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.
Registration/License (if applicable) - active, current registration/license
IRS Reassignment Preference Program (RPP)(if applicable) - 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.
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.
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).
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 USASTAFFING 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 will provide reasonable accommodation to applicants with disabilities on a case-by-case basis; please 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.
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.
Fair and transparent
The Federal hiring process is set up to be fair and transparent. Please read the following guidance.
