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Associate Chief Counsel (Partnerships, S Corporations, Trusts and Estates)

Department of the Treasury
Internal Revenue Service
Office of Chief Counsel, Associate Chief Counsel, Partnerships, S Corporations, Trusts, and Estates
This job announcement has closed

Summary

Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve 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. Please click "Learn more about this agency" to find out more about Chief Counsel's various offices, to view some of the workplace attributes that Chief Counsel's workforce rates most favorably, and to hear from employees themselves.

Overview

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Reviewing applications
Open & closing dates
06/14/2024 to 07/29/2024
Salary
$147,649 to - $221,900 per year
Pay scale & grade
ES 00
Location
Washington, DC
1 vacancy
Remote job
No
Telework eligible
Yes—as determined by the agency policy.
Travel Required
Occasional travel - You may be expected to travel for this position.
Relocation expenses reimbursed
Yes—You may qualify for reimbursement of relocation expenses in accordance with agency policy.
Appointment type
Permanent
Work schedule
Full-time
Service
Senior Executive
Promotion potential
None
Job family (Series)
Supervisory status
Yes
Security clearance
Other
Drug test
No
Position sensitivity and risk
High Risk (HR)
Trust determination process
Announcement number
CCEM-24-12443949-SES
Control number
795863900

This job is open to

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Clarification from the agency

U.S. Citizens and U.S. Nationals; no prior Federal experience is required.

Duties

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As a key member of the executive staff of the Chief Counsel, the Associate Chief Counsel (Partnerships, S corporations, Trusts, and Estates) is responsible for coordinating and directing all activities of the Associate Office for Partnerships, S corporations, Trusts, and Estates, within the Office of Chief Counsel, Internal Revenue Service (IRS).

The Associate Office of Partnerships, S corporations, Trusts, and Estates (Office) is comprised of approximately fifty attorneys, tax law specialists, and support employees in Washington, D.C.; and provides legal advisory services that support the uniform interpretation, application, enforcement, and litigation of tax laws involving a wide range of business and investment entities, including partnerships, S corporations, trusts, and estates (passthrough entities).

The Office manages the classification of domestic and foreign entities and issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift, and generation skipping taxes (referred to collectively as "transfer taxes") and with Treasury officials and IRS Division Commissioners and other Associate and Division Counsel on program matters, such as identifying and prioritizing emerging issues and publishing guidance.

MAJOR DUTIES AND RESPONSIBILITIES:

Major duties include but are not limited to:

  • Serves as the principal legal advisor to the IRS and the Office of Chief Counsel on matters relating to passthrough entities and transfer taxes, publishes public and other technical guidance on such issues, and shares responsibility with the Division Counsel for the direction and oversight of the Counsel-wide litigation program involving passthrough entities and transfer taxes. Represents the IRS and Treasury on sensitive and controversial issues related to these areas.
  • Formulates and directs programs and policies with respect to litigation involving passthrough entities and transfer taxes in the U.S. Tax Court. Assures IRS-wide consistency of approach in tax litigation involving passthrough entities and transfer taxes; consults with the Division Counsel as to the defense or settlement of cases pending in U.S. Tax Court (including the preparation and approval of Chief Counsel actions on decisions) and, reviews and coordinates pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S. Tax Court litigation involving passthrough entities and transfer taxes.
  • Provides executive direction to staff engaged in drafting revenue rulings, revenue procedures, announcements, and news releases to be published for the guidance of taxpayers and IRS personnel; issuing technical advice memoranda responding to questions raised by IRS examiners; issuing private letter rulings and general technical information letters in response to requests from taxpayers; and preparing Chief Counsel Advice and other legal opinions for other Chief Counsel offices and IRS functions with respect to legal questions raised in litigation and IRS programs.
  • Works with Treasury officials to coordinate recommendations for legislation that particularly affects matters involving passthrough entities and transfer taxes; directs IRS participation in this aspect of the legislative process, including the furnishing of advice and guidance with respect to the development of new or revised legislative proposals; oversees IRS participation with legislative staffs in the drafting of such legislation and committee reports.
  • Coordinates the processing and review of nondocketed cases submitted for consideration by various local, area, division, or national levels. Renders legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning issues involving passthrough entities and transfer taxes under examination in the audit of returns, or in the consideration of claims for refund. Develops and monitors performance measures and program goals for the provision of legal services and published guidance, and the implementation, compliance, and outreach initiatives on issues involving passthrough entities and transfer taxes.
  • Plans, directs, and coordinates nationwide programs relating to passthrough entities and transfer taxes, including with respect to all personnel, fiscal and budgetary requests and recommendations. Balances the diverse needs of program segments, and determines the allocation and deployment of human and fiscal resources that best positions the organization to meet the needs of clients as a whole.
  • Directs and oversees the overall management of the division's legal staff. Ensures all management functions are handled equitably and in a manner that is responsive to the needs of all programs that the division supports. Ensures sound position management policy. Takes positive steps in support of all merit system principles.

Requirements

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Conditions of employment

  • Refer to "Additional Information"
  • Click "Print Preview" to review the entire announcement before applying.
  • Must be a U.S. Citizen or National

Qualifications

To qualify for this position of Associate Chief Counsel (Partnerships, S corporations, Trusts, and Estates) you must meet the following requirements:

  • 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;
  • Desired Education/Experience: An LL.M. in Taxation is desired but not required. 7 years of professional legal tax experience is desired.

As a basic requirement for entry into the SES, applicants must provide evidence of progressively responsible leadership experience that is indicative of senior executive level managerial capability and directly related to the skills and abilities outlined under Technical Qualifications and Executive Core Qualifications. Typically, experience of this nature will have been gained at or above the GS-15 grade level or its equivalent in Federal service. Applicants must possess the following technical and executive core qualifications.

You must submit a separate narrative statement that addresses each of the Mandatory Technical Qualifications (MTQs) related to this position as well as the Executive Core Qualifications (ECQs) related to all positions in the Senior Executive Service.

Your narrative statements should include examples of experience, education, and accomplishments applicable to the qualification. Structure your statements in terms of the action taken, the context or environment in which the action was taken, and the outcome or results from such actions. You should write each statement with the vacancy in mind as all qualifications are directly related to the position being filled.

If you do not submit a separate statement addressing the ECQs and MTQs, you will not receive consideration for the position.

A) Executive Core Qualifications (ECQs): Unless you are currently serving under a Career Senior Executive Service (SES) appointment, or eligible for reinstatement into the SES, you must address the ECQs. Applicants must provide a narrative statement (not to exceed a total of 10 pages) that clearly documents and demonstrates possession of the competencies in the Executive Core Qualifications (ECQs) as established by the U.S. Office of Personnel Management. The following five ECQs provide the focus for certification of executive core qualifications for initial career appointment to the Senior Executive Service.

  1. Leading Change - Ability to bring about strategic change, both within and outside the organization, to meet organizational goals. Ability to establish an organizational vision and to implement it in a continuously changing environment.
  2. Leading People - Ability to lead people toward meeting the organization's vision, mission, and goals. Ability to provide an inclusive workplace that fosters the development of others, facilitates cooperation and teamwork, and supports constructive resolution of conflicts.
  3. Results Driven - Ability to meet organizational goals and customer expectations. Ability to make decisions that produce high-quality results by applying technical knowledge, analyzing problems, and calculating risks.
  4. Business Acumen - Ability to manage human, financial, and information resources strategically.
  5. Building Coalitions - Ability to build coalitions internally and with other Federal agencies, State and local governments, nonprofit and private sector organizations, foreign governments, or international organizations to achieve common goals.
Additional information on ECQs is available at: http://www.opm.gov/policy-data-oversight/senior-executive-service/executive-core-qualifications/ . Applicants are strongly encouraged to follow the Challenge, Context, Action and Results model outlined in the guide. It is recommended that you draft your ECQs in a Word document and then upload into the system.

Individuals selected for an initial SES appointment must serve a one-year probationary period.

B) Mandatory Technical Competencies (MTQs):
In addition to the general managerial competencies set out in the Executive Core Qualifications and mandatory for all Senior Executive Service positions, candidates must show evidence of the following more specific competencies in order to meet basic qualifications for this position:

  1. Position requires comprehensive, professional knowledge of and experience in applying tax laws affecting passthrough entities and activities (i.e., partnerships, S corporations, trusts), classification of domestic and foreign entities, and issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift and generation skipping taxes.
  2. Must have demonstrated the ability to manage a legal services program, including the ability to review and assess the organizational effectiveness of program services and policies, and to design and implement procedures to improve/optimize organizational performance.
  3. Must have demonstrated the ability to make effective, decisive, timely and well-considered decisions, and to resolve issues/problems of substantial impact, sensitivity, and complexity.
  4. Must have demonstrated the ability to supervise others to promote maximum utilization and development of staff and to support equal employment opportunity initiative and goals.

C) Desirable:

  1. A thorough understanding of the operations and organization of the Internal Revenue Service and Office of Chief Counsel, and a solid understanding of the Department of the Treasury and its Office of General Counsel.
(Note: Failure to address these factors will result in your application being disqualified.) Narrative responses to the Technical Qualifications and Desirable Qualifications should not be more than two pages for each. Please provide the Executive Core Qualifications, Technical Qualifications and Desirable Qualifications each on separate sheets of paper.

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

  • You may qualify for reimbursement of relocation expenses in accordance with agency policy.
  • This is a Non-Bargaining unit position.
  • We offer opportunities for telework.
  • We offer opportunities for flexible work schedules.
  • The salary range indicated in this announcement covers multiple locality areas.
Conditions of Employment Continued:
  • Subject to a 1-year supervisory probationary period (unless already completed).
  • 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.
  • 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.
  • Public Trust (85PS) Background Investigation required
  • Obtain and use a Government-issued charge card for business-related travel.
  • File a Confidential Financial Disclosure Report OGE-278e 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.
  • This position requires that the successful candidate undergo personnel vetting, which includes a background investigation and enrollment upon onboarding into "Continuous Vetting." Enrollment in Continuous Vetting will result in automated record checks being conducted throughout one's employment with Treasury. The successful candidate will also be enrolled into FBI's Rap Back service, which will allow Treasury to receive notification from the FBI of criminal matters (e.g., arrests, charges, convictions) involving enrolled individuals in near real-time.

    There are three key documents that contain important information about your rights and obligations. Please read and retain these documents:
  • Noncriminal Justice Applicant's Privacy Rights, for those who undergo an FBI fingerprint-based criminal history record check for personnel vetting, which includes Rap Back,
  • FD-258 Privacy Act Statement - FBI (this is the same statement used when your fingerprints are submitted as part of your background investigation), and
  • SEAD-3-Reporting-U.pdf (dni.gov), (applicable to those who hold a sensitive position or have eligibility for access to classified information)"

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.

Candidates found minimally qualified will be further evaluated by an Executive Resources Board based on the extent and quality of their experience as it relates to the Mandatory Technical Competencies and the Executive Core Qualifications needed for this position. Appropriate consideration will be given for job-related training, education, awards, publications, and supervisory appraisals of job performance. Interviews of applicants may be held at the option of the Board. Selected applicant will be subject to certification of their executive qualifications by the U.S. Office of Personnel Management (unless previously certified). (Note: Current and former SES members, and other candidates who have already been OPM/QRB-certified, are not required to address the executive core qualifications. They must, however, provide documentation of certification in the form of an SF-50 showing career SES status, or an OPM issued SES qualification certificate.)

Referral: 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.

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