The Transfer Pricing Practice (TPP) is part of Treaty and Transfer Pricing Operations (TTPO) in the Large Business & International (LB&I) division of the IRS. Transfer pricing essentially involves the pricing of goods, services, and intellectual property transferred between related entities of multinational enterprises (typically corporations with a common parent company). When these transactions involve related entities located in foreign countries, tax issues arise over how much income should be reported in each country. The United States and foreign tax administrations have complex tax rules about how intercompany pricing is to be determined and income reported. It is an area of significant tax controversy, not only in the United States, but also in numerous countries around the world. The IRS Transfer Pricing Practice conducts many types of compliance activities related to transfer pricing. Those activities include examination cases, Compliance Assurance Process (CAP) cases, Campaigns (which may or may not include examinations), assisting with Advance Pricing Agreement matters, and other efforts. The Practice Network supports those working on transfer pricing issues in TTPO by performing risk assessments and identifying emerging issues or issues of strategic importance. In addition, the Practice Network develops training in transfer pricing issues, provides advice to campaigns and assists agents in transfer pricing tax examinations.
The following are the duties of this position at the full working level. If you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and will receive training to help you grow in this position.
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 Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents assigned to a Coordinated Industry or Industry Examination regarding 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 Specialists, International Examiners, 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, International Practice Networks (IPNs)
Participates in long-term projects involving the development of new auditing techniques, work practices, and training programs for Examination Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents. The incumbent develops and conducts training sessions and holds 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.
- We may select from this announcement or any other source to fill one or more vacancies. Additional jobs may be filled.
- This is a Bargaining Unit position.
- Tour of Duty: 8:00 a.m. - 4:30 p.m.
- 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 150-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.
- Must be a U.S. Citizen or National.
- A 1-year probationary period is required.
- Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
- Must successfully complete a background investigation, including a FBI criminal history record check (fingerprint check).
- Complete a Declaration for Federal Employment to determine your suitability for Federal employment, at the time requested by the agency.
- 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.
- 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.
-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))
- 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.
- Relocation expenses - No
- Obtain and use a Government-issued charge card for business-related travel.
- Sign a mobility agreement.
Qualifications
You must meet the following requirements by the closing date of this announcement:
SPECIALIZED EXPERIENCE GS-14:SPECIALIZED EXPERIENCE GS-14: To be minimally qualified for this position you must have (1) one year of specialized experience at a level of difficulty and responsibility equivalent to the grade 13 level in the Federal service. Specialized experience for this position includes: Experience with application of tax law to transfer pricing projects, including application of the Internal Revenue Code, corresponding Treasury Regulations, tax treaties, Court decisions and the Organization for Economic Cooperation and Development (OECD) Guidelines to transfers of tangible and intangible property, high value services, and risk allocation; examining or planning multiple, interrelated transfer pricing issues undertaken by large multinational companies; performing research and analysis of transfer pricing issues; conducting various kinds of analyses verifying taxpayers' economic structure, business practices and functions; reviewing and analyzing economic, financial, operational and financial and tax data to determine the existence of a potential transfer pricing issue; performing analyses to determine and/or evaluate the correct reporting of intercompany transactions; providing technical advice concerning transfer pricing issues on cases; providing advice and recommendations to other employees within issue networks or during workshops and other knowledge sharing forums. Preparing and delivering written and oral communications to explain and defend transfer pricing positions; holding conferences with key corporate tax and other company officials, representatives, and others to present and discuss transfer pricing positions and analysis; and serving, where necessary, as a qualified witness in litigation cases.
YOUR RESUME MUST SUPPORT THE RESPONSES YOU SELECT.
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.
EDUCATION DOCUMENTATION
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.
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.
Additional information
Five (5) Positions are to be filled in any of the following locations:
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: This position will be filled through the Direct Hire Authority. Under this authority, competitive rating, ranking, and veterans' preference procedures do not apply. Your application will be considered based on education, training, and quality of your experience. For more information on Direct-Hire Authority visit: OPM Direct Hire Fact Sheet.
Referral: Applicants who meet the basic qualification requirements may be referred to a selecting official for consideration. Candidates 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 practices). We will not reimburse costs related to the interview such as travel to and from the interview site.
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 for this Public Notice:
Resume - For qualification determinations your resume (uploaded or created in USAJOBS) must contain hours worked per week and dates of employment (i.e., month/year to month/year or month/year to present). If your resume does not contain this information, your application may be marked as insufficient and you will not receive consideration for this position. If you are a current Federal employee or previous Federal employee, provide your pay plan, series and grade, i.e. GS-0301-09. Do NOT include photographs (or links to social media such as LinkedIn), inappropriate material, inappropriate content, nor personal information such as age, gender, religion, social security number, etc., on your resume. (Cover letters are optional.) Please view Resume Tips.
Online Application - Questionnaire
Proof of Enrollment or Education - 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. 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. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. Click here for Foreign Education Credentialing instructions.
Registration/License (IF APPLICABLE) - active, current registration/license
Veterans' Preference (IF APPLICABLE) - If you are claiming veterans' preference, 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. Ten-point preference eligibles must also submit an Application for 10-point Veteran Preference, SF-15, along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference view FedsHireVets.
Military Spouses - You MUST submit verification of the marriage to the service member(i.e., a marriage license or other legal documentation verifying marriage) AND (1) a copy of your spouse's active military orders; OR (2) verification of your spouse's 100% service-connected disability (e.g., VA Letter and/or DD-214); OR (3) 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.
Current and Former Federal Employees Documentation - You MUST submit a copy of your most recent SF-50 (Notification of Personnel Action) or equivalent personnel action form which shows your current grade and competitive service status. (The "position occupied" block on the SF-50 should show a "1" and your "tenure" block should be a "1" or "2".) It is recommended to also provide an additional SF-50(s) (or equivalent), if you are applying for a higher grade which clearly demonstrates you meet the 52-week time-in-grade requirement (e.g., Promotion with an effective date more than one (1) year old, Within-Grade-Increase at the highest grade held).
Career Transition Assistance Plan (CTAP) (IF APPLICABLE) - IRS CTAP eligibles can apply for jobs within and outside the commuting area. Treasury CTAP eligibles can apply for jobs within the commuting area. Find required documentation at: Career Transition Assistance Plan (CTAP).
Interagency Career Transition Assistance Plan (ICTAP) (IF APPLICABLE) - If you are a displaced or surplus Federal employee, click CTAP/ICTAP for eligibility and a detailed list of required documents.
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).
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 05/28/2021 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 the announcement's closing date.
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 05/28/2021.
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/.
LBI - 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.
Our comprehensive benefits are very generous. Our benefits package includes:
Challenging work, opportunities for advancement, competitive salaries, bonuses and incentive awards.
Ten paid holidays, 13 days of sick leave, and 13 to 26 days of vacation time each year.
Access to insurance programs that may be continued after you retire.
A wide choice of health insurance plans, coverage for pre-existing conditions, and no waiting periods. We pay a substantial amount (up to 75%) of the health insurance premiums.
A retirement program which includes employer-matching contributions.
The following documents are required and must be provided with your application for this Public Notice:
Resume - For qualification determinations your resume (uploaded or created in USAJOBS) must contain hours worked per week and dates of employment (i.e., month/year to month/year or month/year to present). If your resume does not contain this information, your application may be marked as insufficient and you will not receive consideration for this position. If you are a current Federal employee or previous Federal employee, provide your pay plan, series and grade, i.e. GS-0301-09. Do NOT include photographs (or links to social media such as LinkedIn), inappropriate material, inappropriate content, nor personal information such as age, gender, religion, social security number, etc., on your resume. (Cover letters are optional.) Please view Resume Tips.
Online Application - Questionnaire
Proof of Enrollment or Education - 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. 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. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. Click here for Foreign Education Credentialing instructions.
Registration/License (IF APPLICABLE) - active, current registration/license
Veterans' Preference (IF APPLICABLE) - If you are claiming veterans' preference, 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. Ten-point preference eligibles must also submit an Application for 10-point Veteran Preference, SF-15, along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference view FedsHireVets.
Military Spouses - You MUST submit verification of the marriage to the service member(i.e., a marriage license or other legal documentation verifying marriage) AND (1) a copy of your spouse's active military orders; OR (2) verification of your spouse's 100% service-connected disability (e.g., VA Letter and/or DD-214); OR (3) 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.
Current and Former Federal Employees Documentation - You MUST submit a copy of your most recent SF-50 (Notification of Personnel Action) or equivalent personnel action form which shows your current grade and competitive service status. (The "position occupied" block on the SF-50 should show a "1" and your "tenure" block should be a "1" or "2".) It is recommended to also provide an additional SF-50(s) (or equivalent), if you are applying for a higher grade which clearly demonstrates you meet the 52-week time-in-grade requirement (e.g., Promotion with an effective date more than one (1) year old, Within-Grade-Increase at the highest grade held).
Career Transition Assistance Plan (CTAP) (IF APPLICABLE) - IRS CTAP eligibles can apply for jobs within and outside the commuting area. Treasury CTAP eligibles can apply for jobs within the commuting area. Find required documentation at: Career Transition Assistance Plan (CTAP).
Interagency Career Transition Assistance Plan (ICTAP) (IF APPLICABLE) - If you are a displaced or surplus Federal employee, click CTAP/ICTAP for eligibility and a detailed list of required documents.
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).
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 05/28/2021 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 the announcement's closing date.
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 05/28/2021.
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/.
LBI - 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.
Our comprehensive benefits are very generous. Our benefits package includes:
Challenging work, opportunities for advancement, competitive salaries, bonuses and incentive awards.
Ten paid holidays, 13 days of sick leave, and 13 to 26 days of vacation time each year.
Access to insurance programs that may be continued after you retire.
A wide choice of health insurance plans, coverage for pre-existing conditions, and no waiting periods. We pay a substantial amount (up to 75%) of the health insurance premiums.
A retirement program which includes employer-matching contributions.
