Clarification from the agency

Open to IRS Career/Career-Conditional, Treasury/IRS CTAP, & IRS RPP employees

WHAT IS THE APPEALSDIVISION?
A description of the business units can be found at: https://www.jobs.irs.gov/about/who/business-divisions

Vacancies will be filled in the following specialty areas:
C&OS, Specialized Exam Programs & Referrals (SEP&R), Area 11
The following are the duties of this position at the full working level. If this vacancy includes more than one grade and you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and receive training to help you grow in this position.

Conducts Appeals conferences for the settlement/resolution of the largest and most complex international tax cases in which taxpayers have appealed determinations made by the Service or have filed petitions with the U.S. Tax Court for redetermination of tax liability. Cases typically concern large, complex businesses, including those with extensive subsidiaries, diversified activities, multiple partners and national or international scope of operations.

Receives cases and works issues which have been referred by Appeals management when the complexity of the international tax issues warrants the services of an International Specialist.

Reviews international case files, supporting documents, and other information germane to the determination of tax liability. Analyzes case files to determine issues of fact and law. As needed, obtains and evaluates expert testimony or information in highly technical areas such as engineering, finance, science, art, etc. to resolve complex valuation issues. *Reconciles apparent factual discrepancies by further investigation, reconstruction, and/or the determination of the interpretation most consistent with all available evidence.

Conducts extensive research and analysis of international tax issues to determine and apply the law to the highly complex factual and policy issues presented. Exercises a high degree of judgment in conducting original and creative legal research to obtain a reasonable balance of conflicting interests in determining a resolution. Serves as an expert in determining a final settlement on cases where the law is unclear: laws and regulations may be highly subjective, obscure or conflicting, or case law may be conflicting, lack precedent or clear interpretation. In such instances, determines the appropriate resolution for large dollar or sensitive issues based upon relevant factors including reasonableness, adjudication trends and settlement practices. May raise alternative arguments when appropriate.

Serves as an "in-house" expert and/or office liaison on international tax issues where there is little or no previous interpretation of statutory provisions, laws and regulations are highly subjective, precedents are nonexistent, obscure or conflicting, and there are significant amounts of tax at issue. Provides assistance, information, and guidance on international tax issues to Team Case Leaders, Appeals Officers, Appeals Tax Computation Specialists, and other technical staff. Reviews proposed settlements of coordinated issues and conveys concurrence or disagreement. Disagreements will be conveyed in writing.

Conditions of employment

STANDARD POSITION DESCRIPTIONS (SPD):
PD92066 and PD92066
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.
• Obtain and use a Government-issued charge card for business-related travel.

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: You must have one 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 all of the following: Experience applying professional accounting principles, theory, and practices to analyze and interpret accounting books, records, or systems specifically to determine the effect on tax liabilities or financial statements; Experience using accounting or legal knowledge of tax implications to make financial or business decisions; Experience recognizing and assessing the complexity of accounting or legal issues; Experience applying professional legal principles, theory, and practices to analyze and interpret legal issues specifically to determine effect on tax liabilities or financial statements; Interpreting the law in situations where there are uncertainties or conflicts in statutes, regulations, case law, precedence or other guidance to determine and apply the appropriate intent of the law in tax situations; Experience conducting legal research and applying the law to tax situations; Familiar with litigation procedures and making judgments involving matters of law particularly as they relate to resolving tax disputes.
In addition to the above you must have experience reviewing analyzing tax treaties between the United States and foreign governments to apply and resolve cases relevant to tax laws in foreign countries, economic theory, exchange rates, contract laws, immigration laws, and bank secrecy laws. Experience in applying tax and accounting principles in the resolution of tax disputes. Such topics may include one or more of the following: shifting of income (through improper pricing or transfer of intangibles), foreign tax credits, Subpart-F, organizational restructuring/cross border mergers and acquisitions involving foreign entities, foreign corporation distributions including liquidations, repatriations, and dividend distributions, permanent establishment issues, effectively connected income and proper sourcing of income, determining assessment and abatement of international penalties and Title 31 penalties.

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".

For more information on qualifications please refer to OPM's Qualifications Standards.

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 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.