This job originated on www.usajobs.gov. For the full announcement and to apply, visit www.usajobs.gov/job/557643000. Only resumes submitted according to the instructions on the job announcement listed at www.usajobs.gov will be considered.
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.
Learn more about this agency01/24/2020 to 06/19/2020
$121,316 - $157,709 per year
GS 14
Yes—as determined by the agency policy.
Occasional travel - Limited travel may be required.
No
Permanent
Full-Time
Excepted
14
No
No
CCED-20-23
557643000
U.S. Citizens and U.S. Nationals; no prior Federal experience is required.
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:
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.
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, and certain homeowner associations.
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.
Please note this list of duties is not all inclusive.
NOTE: This is an open-continuous announcement that will open January 24, 2020 to December 31st, 2020. Referral lists will be issued after the first of every 3 months starting on May 1, 2020 through January 1st, 2021 or as vacancies occur, whichever is first. Cutoff for receipt of applications will be midnight EST on the first of the month. Applications received after the cutoff date, may be considered on future referral lists. The announcement may close prior to December 31st, if management has succeeded in filling all vacancies and has no further use for a standing register.
UPDATED NOTE 6/16/2020: Announcement closing date has been changed to 6/19/2020. At that time all remaining applications will be referred if applicable. A similar announcement, CCED-20-89, will open on June 22, 2020.
CONDITIONS OF EMPLOYMENT:
You must meet the following requirements by the cut-off dates of this announcement:
GS-14:
OR
In addition, 2 Years of Specialized experience is required and is defined as the following for each Business Unit:
Corporate: At least 2 years of the legal tax experience must have involved experience working on the application of Federal Income Tax laws concerning Subchapter C and the consolidated return regulations to complex corporate transactional issues.
Financial Institutions and Products: At least 2 years of legal tax experience must have included tax matters involving financial institutions; the taxation of financial products or transactions including deposits, debt instruments, options, forwards, futures, notional principal contracts, and other derivative financial products, virtual currency, or other financial transactions; the taxation of gain or loss on disposition of property; or cross-border aspects of financial institutions and financial products
Income Tax and Accounting: At least 2 years of legal tax experience working on tax accounting issues, such as: recognition and timing of income and deductions, sales and exchanges, capital gains and losses, accounting methods and periods, installment sales, long term contracts, and inventories, and assignments involving complex and difficult legal questions requiring extensive research, analysis, and evaluation.
International: At least 2 years of 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, income tax treaties, subpart F, foreign tax credits and sourcing of income and deductions, international corporate and partnership issues, cross-border financial transactions, transfer pricing, and withholding, 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: At least 2 years of the legal tax experience must include tax experience in either of the following two areas of Federal tax law: Certain general business credits under § 38, subchapter T cooperatives, personal holding companies, § 118 contributions to the capital of a corporation, and § 199 deduction for domestic production activities. OR Taxation matters concerning the research credit, as well as all phases of energy production.
Employee Benefits, Exempt Organizations, and Employment Taxes: 2 years of the legal tax experience must have involved experience handling of sophisticated legal issues and interpretation and/or compliance work related to exempt organizations tax issue, employment taxes, Health and Welfare tax issues, Qualified Plans, or executive compensation.
Other qualifications for this position include:
You must have graduated with a J.D. and/or LL.M. from an ABA-accredited law school.
Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from schools accredited by accrediting institutions recognized by the U.S. Department of Education.
If you are qualifying based on foreign education, you must submit proof of credibility of education as evaluated by a credentialing agency. Refer to the OPM instructions.
Other Information:
You will be evaluated for this job based on how well you meet the qualifications above.
Rating: Your application will be evaluated using the experience/education defined under the qualifications section.
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 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.
If selected, you will be required to submit an original Certificate of Good Standing from your State Bar.
Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from schools accredited by accrediting institutions recognized by the U.S. Department of Education.
Failure to provide all of the required information as stated in this vacancy announcement may result in an ineligible rating or may affect the overall rating.
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) by each cutoff date or by the closing date of this announcement. We are available to assist you during business hours (7:00 a.m. - 3:30 p.m. CST, Monday - Friday). If applying online poses a hardship, please contact us by noon ET on the announcement's closing date. Treasury provides 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.
To begin, either click the Create a New Account button and follow the prompts to register or if you previously registered, click the Apply Online button and follow the prompts.
If you are experiencing system issues with your application, please contact the CareerConnector Help Desk at careerconnectorhelp@do.treasury.gov and/or the USAJOBS Help Desk.
To check the status of your application for this position, please follow these steps:
If the "additional application information" link is not available and the vacancy is still open, you can click on the job announcement and "Update Application" to be taken back to the CareerConnector portion of the application.
Please notify us if your contact information changes after the closing date of the announcement. Also, note that if you provide an email address that is inaccurate or if your mailbox is full or blocked (e.g., spam-blocker), you may not receive important communication that could affect your consideration for this position.
The Federal hiring process is set up to be fair and transparent. Please read the following guidance.
This job originated on www.usajobs.gov. For the full announcement and to apply, visit www.usajobs.gov/job/557643000. Only resumes submitted according to the instructions on the job announcement listed at www.usajobs.gov will be considered.
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