Office of Chief Counsel, IRS, is looking for enthusiastic individuals to join our team and gain valuable experience in a legal environment. Our mission is to serve America's taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. It is a great place to work with an excellent benefits package and family-friendly atmosphere.
Summary
Office of Chief Counsel, IRS, is looking for enthusiastic individuals to join our team and gain valuable experience in a legal environment. Our mission is to serve America's taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. It is a great place to work with an excellent benefits package and family-friendly atmosphere.
Office of Chief Counsel, IRS, the largest tax law firm in the country, is looking for enthusiastic individuals to join our team and gain valuable experience in a legal environment. Our mission is to serve America's taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. It is a great place to work with an excellent benefits package and family-friendly atmosphere.
This announcement is being used to fill positions within multiple Business Units in the Office of Chief Counsel. As a GS-14 General Attorney (Tax) for the Associate Chief Counsel, you will perform the following principal duties within your assigned Business Unit and expertise:
Draft published guidance, including regulations, revenue rulings, revenue procedures, etc.
Provide written legal advice to taxpayers and field components of the IRS.
Make recommendations regarding litigation; review briefs and other litigation-related documents.
The following are additional duties within assigned Business Units:
Corporate: Provides legal advice, litigation services and litigation support on matters involving corporate organizations, reorganizations, liquidations, spin-offs, transfers to controlled corporations, distributions to shareholders, debt vs. equity determinations, bankruptcies, and consolidated return issues affecting groups of affiliated corporations among other matters.
Employee Benefits, Exempt Organizations, and Employment Taxes: Provides legal advice, litigation services and litigation support on matters involving employee benefits including qualified retirement plans, IRAs, executive compensation arrangements, and health and welfare plans, exempt organizations, employment taxes, and certain issues related to federal, state, local and Indian tribal governments.
Financial Institutions and Products: Provides legal advice, litigation services and litigation support on tax matters involving financial institutions and the taxation of financial products to include banks, thrift institutions, insurance companies, regulated investment companies, real estate investment trusts, asset securitization arrangements, life insurance contracts, annuities, options, futures contracts, original issue discount obligations, hedging arrangements, and government entities issues including tax-exempt bonds and other types of innovative financial instruments and entities.
Income Tax and Accounting: Provides legal advice, litigation services and litigation support on tax matters involving recognition and timing of income and deductions by individuals and corporations, sales and exchanges, capital gains and losses, accounting methods and periods, depreciation and other cost recovery issues, installment sales, long-term contracts, inventories and alternative minimum tax.
International: Provides legal advice, technical guidance (including guidance published in the Federal Register and/or Internal Revenue Bulletin), and litigation support on matters involving the international provisions of the United States revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party. Participates in the Organization for Economic Cooperation and Development (OECD) as a delegate to the United States.
Passthroughs and Special Industries: Provides legal advice, litigation services and litigation support on tax matters involving income taxes of S corporations, partnerships (including limited liability companies), trusts, estates, gifts, generation-skipping transfers, certain excise taxes, income tax credits, cooperative housing corporations, farmers' and other cooperatives, low-income housing credit, research and expenditures, taxation concerning natural resources and energy production, and certain homeowner associations.
Please note this list of duties is not all inclusive.
NOTE: This is an open-continuous announcement that is open January 19, 2022 to June 30, 2022. Applicants will be referred to the selecting officials and referral lists issued as vacancies occur.
Cutoff for receipt of applications will be midnight EST on the date a vacancy has been determined. Applications received after that date, may be considered on future referral lists. Notifications will be sent to applicants when application has been referred or not referred. The announcement may close prior to June 30, 2022, if management has succeeded in filling all vacancies and has no further use for a standing register.
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Must be a U.S. Citizen or National
Qualifications
In order to qualify, you must meet the education and/or experience requirements described below. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.
To qualify for this position of General Attorney (Tax) you must meet the qualification requirements listed below by the closing of this announcement:
Basic Requirements for General Attorney (Tax):
Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; AND
Applicants must be an active member in good standing of the bar of a State, U.S. Commonwealth, U.S. territory, the District of Columbia, or the Commonwealth of Puerto Rico;
GS-14 Experience Requirements:
1 year of general legal experience; plus
2 year(s) of legal tax experience
Legal Tax Experience is defined as legal work in one of following areas of tax expertise: Corporate; Financial Institutions and Products; Income and Products; Income Tax and Accounting; International; Passthroughs and Special Industries; or Employee Benefits, Exempt Organizations, and Employment Taxes.At least one year of this experience must be equivalent to the work performed at the next lower grade/level position in the federal service (GS-13).
Tax Area Expertise may include, but not limited to the following experience:
Corporate: Experience working on the application of Federal Income Tax laws concerning Subchapter C and the consolidated return regulations to complex corporate transactional issues, including corporate organizations, reorganizations, liquidations, spin-offs, transfers to controlled corporations, distributions to shareholders, debt vs. equity determinations, bankruptcies, and consolidated return issues affecting groups of affiliated corporations among other matters.
Financial Institutions and Products: Tax matters involving financial institutions and financial products, including the taxation of banks, insurance companies, regulated investment companies, real estate investment trusts, asset securitization arrangements, life insurance contracts, annuities, notional principal contracts, options, forwards, futures, debt instruments (including original issue discount obligations and tax-advantaged bonds), hedging arrangements, and other types of innovative financial instruments and entities.
Income Tax and Accounting: Providing legal advice and litigation support on tax matters involving recognition and timing of income and deductions of individuals and corporations, sales and exchanges, capital gains and losses, accounting methods and periods, installment sales, long-term contracts, inventories and alternative minimum tax to the Internal Revenue Service, the Office of Chief Counsel, the Department of the Treasury, or to other government agencies and the public.
International: Legal tax experience in U.S. international tax matters. Such experience includes taxation of inbound or outbound investment, including areas such as the TCJA provisions, subpart F, foreign tax credits, sourcing of income and deductions, income tax treaties, cross-border financial transactions, international corporate and partnership issues, transfer pricing, withholding, and exchange of information, in the context of planning, examination, and/or litigation, and assignments involving complex and difficult legal questions requiring extensive research, analysis, and evaluation.
Passthroughs and Special Industries: Taxation matters involving passthrough entities, including the income taxation of partnerships (including limited liability companies), S corporations, trusts, and their owners and beneficiaries, the classification of entities, the taxation of estates, gifts, and generation-skipping transfers, income tax credits, cooperative housing corporations, farmers' and other cooperatives, low-income housing credits, research and experimental expenditures, taxation concerning natural resources and energy production, certain homeowner associations, and certain excise tax issues.
Employee Benefits, Exempt Organizations, and Employment Taxes: Experience handling sophisticated legal issues related to the interpretation of, and compliance with: employment taxes (including worker classification, fringe benefits, and self-employment tax); the taxation of employee benefits, exempt organizations (including charities, private foundations, UBIT, and related excise taxes), health and welfare plans, retirement plans (including qualified plans and IRAs), and executive compensation; and certain issues related to government entities (including Indian tribal governments) .
Education Substitution: An LL.M. degree in the field of the position (tax, GLS-related, or P&A- FOIA/Disclosure related field) may be substituted for the one year of the general legal experience listed above.
Experience refers to paid and unpaid experience, including volunteer work done through National Service programs (e.g., Peace Corps, AmeriCorps) and other organizations (e.g., professional; philanthropic; religious; spiritual; community; student; social). You will receive credit for all qualifying experience, including volunteer experience. 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.
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 page.
FOREIGN EDUCATION: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. For further information, visit: http://www.ed.gov/about/offices/list/ous/international/usnei/us/edlite-visitus-forrecog.html.
Additional information
We may select from this announcement or any other source to fill one or more vacancies.
Relocation expenses are not authorized.
This is abargaining unit position.
We offer opportunities for telework.
We offer opportunities for flexible work schedules.
Conditions of Employment Continued:
Subject to a 1-year trial period (unless already completed).
Subject to a Tenure Commitment of up to 3 years
Must successfully complete a background investigation.
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.
Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
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.
Obtain and use a Government-issued charge card for business-related travel.
File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on.
Undergo an income tax verification.
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.
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 or enforce the COVID-19 vaccination requirement pursuant to Executive Order 14043 on Requiring Coronavirus Disease 2019 Vaccination for Federal Employees. Therefore, to the extent a Federal job announcement includes the requirement that applicants must be fully vaccinated against COVID-19 pursuant to Executive Order 14043, that requirement does not currently apply. 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.
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.
Applicants will be considered based on their overall background as it relates to the position to be filled. Interviews may be held at the option of the office. All application materials and interviews, if conducted, will be used in the final evaluation and selection process.
Referral: Professional Order will be used to refer and select eligible candidates. Veterans' preference is applied after applicants are assessed. Preference eligibles will be listed at the top of the certificate in alphabetical order and considered before non-preference eligibles. All other candidates will be listed in alphabetical order. If you are among the top qualified candidates, 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.
Bargaining Unit Chief Counsel employees will be given first consideration. To receive first consideration, Bargaining Unit Chief Counsel employees seeking reassignment must be on the Master First Consideration List (MFCL). In regard to this announcement, the MFCL is only for reassignments of employees currently occupying Bargaining Unit positions. If you are applying for a promotion, please apply to the announcement.
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.
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 may 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.) 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.
In addition, applicants are required to submit: 1. An unofficial or official transcript(s) for your J.D. degree or LL.M. degree (an official transcript is required if you are selected); 2. An 8-10 page legal writing sample; and 3. A memorandum of interest summarizing your interest in the position.
VETERANS' PREFERENCE DOCUMENTATION: There is no formal rating system for applying veterans' preference to attorney appointments in the excepted service; however, the Office of Chief Counsel considers veterans' preference eligibility as a position factor in attorney hiring. If you are claiming veterans' preference, you must submit a copy of your Certificate of Release or Discharge from Active Duty, 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.
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. See "Education" for more details.
If selected, you will be required to submit an original Certificate of Good Standing from your State Bar.
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 06/30/2022 and/or cut-off dates in this announcement. We are available to assist you during business hours (normally 7:00-3:00. ET, Monday - Friday). To preview the Application Questionnaire, please click the following link: https://apply.usastaffing.gov/ViewQuestionnaire/11346283
To begin, click Apply to access the online application. You will need to be logged into your USAJOBS account to apply. If you do not have a USAJOBS account, you will need to create one before beginning the application.
Follow the prompts to select your resume and/or other supporting documents to be included with your application package. You will have the opportunity to upload additional documents to include in your application before it is submitted. Your uploaded documents may take several hours to clear the virus scan process.
After acknowledging you have reviewed your application package, complete the Include Personal Information section as you deem appropriate and click to continue with the application process.
You will be taken to the online application which you must complete in order to apply for the position. Complete the online application, verify the required documentation is included with your application package, and submit the application. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete.
It is your responsibility to verify that your application package (resume, supporting documents, and responses to the questionnaire) is complete, accurate, and submitted by the closing date. Uploaded documents may take up to one hour to clear the virus scan.
Additional information on how to complete the online application process and submit your online application may be found on the USA Staffing Applicant Resource Center.
Office of Chief Counsel, IRS
1111 Constitution Ave., NW
Washington, DC 20224
US
Next steps
To verify the status of your application, log into your USAJOBS account (https://my.usajobs.gov/Account/Login), all of your applications will appear on the Welcome screen. 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/.
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 may 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.) 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.
In addition, applicants are required to submit: 1. An unofficial or official transcript(s) for your J.D. degree or LL.M. degree (an official transcript is required if you are selected); 2. An 8-10 page legal writing sample; and 3. A memorandum of interest summarizing your interest in the position.
VETERANS' PREFERENCE DOCUMENTATION: There is no formal rating system for applying veterans' preference to attorney appointments in the excepted service; however, the Office of Chief Counsel considers veterans' preference eligibility as a position factor in attorney hiring. If you are claiming veterans' preference, you must submit a copy of your Certificate of Release or Discharge from Active Duty, 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.
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. See "Education" for more details.
If selected, you will be required to submit an original Certificate of Good Standing from your State Bar.
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 06/30/2022 and/or cut-off dates in this announcement. We are available to assist you during business hours (normally 7:00-3:00. ET, Monday - Friday). To preview the Application Questionnaire, please click the following link: https://apply.usastaffing.gov/ViewQuestionnaire/11346283
To begin, click Apply to access the online application. You will need to be logged into your USAJOBS account to apply. If you do not have a USAJOBS account, you will need to create one before beginning the application.
Follow the prompts to select your resume and/or other supporting documents to be included with your application package. You will have the opportunity to upload additional documents to include in your application before it is submitted. Your uploaded documents may take several hours to clear the virus scan process.
After acknowledging you have reviewed your application package, complete the Include Personal Information section as you deem appropriate and click to continue with the application process.
You will be taken to the online application which you must complete in order to apply for the position. Complete the online application, verify the required documentation is included with your application package, and submit the application. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete.
It is your responsibility to verify that your application package (resume, supporting documents, and responses to the questionnaire) is complete, accurate, and submitted by the closing date. Uploaded documents may take up to one hour to clear the virus scan.
Additional information on how to complete the online application process and submit your online application may be found on the USA Staffing Applicant Resource Center.
Office of Chief Counsel, IRS
1111 Constitution Ave., NW
Washington, DC 20224
US
Next steps
To verify the status of your application, log into your USAJOBS account (https://my.usajobs.gov/Account/Login), all of your applications will appear on the Welcome screen. 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/.
Fair and transparent
The Federal hiring process is set up to be fair and transparent. Please read the following guidance.
