Clarification from the agency

Open to U.S. Citizens/Nationals

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WHAT IS THE APPEALS AND LARGE BUSINESS & INTERNATIONAL DIVISION?

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:

Independent Office of Appeals: C&OS; Collection Appeals; Examination Appeals; and SEP&R. Independent Office of Appeals: C&OS; Collection Appeals; Examination Appeals; and SEP&R.

Large Business and International Director Treaty and Trans Pric Ops-Advance Pricing and Mutual Agreement.

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.

• Holds conferences and negotiates issues with taxpayers/representative to resolve tax disputes in a fair and impartial manner. Taxpayers are often officers of publicly traded companies and representatives are typically from the most prestigious national law and accounting firms.
• Area 9 is a national program made up of four teams located throughout the country. Area 9 has primary responsibility for the largest cases in Appeals, generally Large Corporate Compliance Program Cases (LCC) and Industry Cases (IC) with multiple complex tax issues with over $10 million dollars in dispute. This work is accomplished by the incumbent and a team of several employees. Team members are typically experts in a particular aspect of federal taxation and are often grade 14 Technical Specialists, International Specialists or Appeals Officers.
• Communicates and fosters dialogue with peers, customers and partners. Leads several teams that work cases and coaches individual employees in the accomplishment of team objectives and effective problem-solving.
• Advises and coaches team members regarding their team assignments. Provides appropriate and substantive feedback on team assignments to the team member and his/her immediate manager. This feedback is both written and oral; provided on a timely and ongoing basis; addresses the appropriate critical job elements and aspects; and follows guidelines prescribed by the Chief Appeals, the Director, and the Appeals Area Director as to timing, form and content of the feedback.
• Apprises management of critical or sensitive work related matters. Provides recommendations that are technically authoritative and generally determinative as to actions taken. These include advising on the selection, development, training and tenure of team members; determining the effect of and responsibility for statute expirations; independently recommending resolutions of work related issues involving team members; and delineating the impact on compliance arising from a proposed settlement.
• Reviews Advance Pricing Agreement (APA) requests and taxpayer requests for assistance in obtaining relief from double taxation to determine if such requests comply with procedural guidelines.
• Performs a balanced and critical analysis of taxpayer and treaty partner proposals and performs due diligence to ensure that the facts and circumstances of the taxpayer's case are sufficiently understood to arrive at a legally supportable determination.
• Evaluates, analyzes, and develops the positions of the United States with respect to complex transfer pricing issues and other international tax issues.
• Leads IRS projects to determine the best transfer pricing method and position to adopt in a given case in a timely manner.
• Leads and works cooperatively within teams of IRS employees (notable international examiners, economists, and attorneys) and independently develops facts, issues, analysis, and conclusions as needed. Secures additional information directly from taxpayers or from treaty partners in furtherance of these goals when necessary.

Conditions of employment

• Telework Eligible Positions: Telework eligible positions do not guarantee telework. Employees must meet and sustain IRS telework eligibility requirements (e.g., reporting at least twice a pay period to your assigned Post of Duty (POD)) and supervisor's approval to participate in the IRS Telework Program. Employees must also be within a 200-mile radius of their official assigned post-of-duty (POD) while in a telework status. 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 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).
• Complete a Declaration for Federal Employment to determine your suitability for Federal employment, at the time requested by the agency.
• 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 unexpired original 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.

SPECIALIZED EXPERIENCE GS-11: To be minimally qualified for this position you must have at least one year of specialized experience equivalent to the next lower level in the normal line of progression. Specialized experience for this position includes: One (1) year of specialized experience at a level of difficulty and responsibility equivalent to the GS-9 grade level in the Federal service. Experience in applying tax law to resolve tax issues and/or erroneous penalty assessments. Applying current and past Internal Revenue Code and related laws, tax laws, court decisions, and regulations to negotiate tax disputes. Experience researching tax related information from a variety of sources (for example, Internal Revenue Manual, IR Code Regulations, commercial databases, court and revenue rulings). Experience reviewing financial books and records to advise individuals on tax ramifications. Experience applying the hazards of litigation to the facts and circumstances of tax disputes. Providing tax law advice or guidance to taxpayers, clients or employer. Experience applying general business practices and basic accounting and financial analysis techniques to analyze financial information (e.g., analyzing taxpayer transcripts, case files, financial documents and records and other information). Experience in verbal, written, and/or virtual communications, preparing and conducting presentations, briefings, training, etc. regarding tax related issues. Experience mediating/negotiating the resolution of a tax dispute between government and individual/business (i.e. sole proprietors and individuals with business and supplemental income) taxpayers.
OR
You may substitute education for specialized experience as follows: A Ph.D. or equivalent doctoral degree in a field of study such as: law, accounting, business or management, economics, math, and finance or 3 full years of progressively higher-level graduate education leading to a doctoral degree in a field of study such as law, accounting, business or management, economics, math, and finance. One year of graduate education is creditable in accordance with its relationship to a year of full-time study at the school attended.
OR
You may qualify by a combination of experience and education. Options for qualifying based on a combination will be identified in the online questions.

SPECIALIZED EXPERIENCE GS-12: Applicants must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-11 grade level in the Federal service. Specialized experience for this position includes: experience in applying tax law to resolve tax issues and/or erroneous penalty assessments. Applying current and past Internal Revenue Code and related laws, tax laws, court decisions, and regulations to negotiate tax disputes. Experience researching tax related information from a variety of sources (for example, Internal Revenue Manual, IR Code Regulations, commercial databases, court and revenue rulings). Experience reviewing financial books and records to advise individuals and businesses on tax ramifications. Experience applying the hazards of litigation to the facts and circumstances of tax disputes. Experience providing tax law advice or guidance to taxpayers, clients or employer. Experience applying general business practices and standard accounting and financial analysis techniques to analyze financial information (e.g., analyzing taxpayer transcripts, case files, financial documents and records and other information). Experience in verbal, written, and/or virtual communications, preparing and conducting presentations, briefings, training, etc. regarding tax related issues. Experience mediating/negotiating the resolution of a tax dispute between government and individual or business (i.e. sole proprietors and individuals with business and supplemental income, small partnerships and corporations) taxpayers.

SPECIALIZED EXPERIENCE GS-13: Applicants must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-12 grade level in the Federal service. Specialized experience for this position includes: experience in applying tax law or accounting principles to resolve tax issues. Applying current and past Internal Revenue Code and related laws, tax laws, court decisions, regulations, accounting principles and practices to analyze accounting documents, books, and records specifically to resolve tax disputes. Experience 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; Experience applying the hazards of litigation to the facts and circumstances of tax disputes. Experience providing tax law advice or guidance to taxpayers, clients or employer. Experience in verbal, written, and/or virtual communications, preparing and conducting presentations, public forums, briefings, training, etc. regarding tax related issues. Experience mediating/Negotiating the resolution of tax disputes between government and business or individual taxpayers.

SPECIALIZED EXPERIENCE GS-14: 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 applying tax law and/or accounting principles, theory and practices to analyze and interpret accounting records or legal issues to resolve tax issues or determine tax liabilities. Experience preparing, examining, interpreting and analyzing financial statements of multiple entities (e.g., corporations, partnerships, estates, trusts) to resolve tax disputes; Experience with General Accepted Accounting Principles (GAAP) process from financial to tax administration. Experience conducting legal research and 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 applying litigation procedures and making judgments involving matters of law particularly as they relate to resolving tax disputes. Experience providing tax law advice or guidance to clients or employer; Experience negotiating the resolution of tax disputes between government and corporate or individual taxpayers. Experience negotiating the resolution of legal tax disputes arising from corporate consolidations, mergers, or estate and gift tax valuation issues.

Qualification continues in Education...

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.

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.

Your application must include 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.

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.

If you are a displaced Federal employee (eligible for the Interagency Career Transition Assistance Plan (ICTAP), you must be found "well qualified" for the position. Well qualified is defined as: experience that exceeds the minimum qualifications of the position, demonstrated by meeting all the competencies for this position.