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In order to qualify, you must meet the education and/or experience requirements detailed below by the closing date of this announcement. 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) - Senior Counsel, you must meet the qualification requirements listed below by the closing of this announcement: Basic Requirements for General Attorney (Tax) - Senior Counsel: 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-15 Experience Requirements: 1 year of general professional legal experience from any area of expertise; plus 3 years of professional legal tax experience Professional Legal Tax Experience is defined as: Performing legal research and/or providing legal guidance in federal tax controversy, federal tax litigation, or federal tax consulting. Drafting of guidance for international provisions of US tax laws; Exchange of information under tax treaties and other international agreements in civil and criminal tax cases under the IRS Tax Code; Information or evidence collection in complex situations regarding foreign countries; Resolving procedural foreign law problems; Transfer pricing issues and treaty interpretation; and Litigation support to others and the Department of Justice (DOJ) on international tax issues. 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-14). Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience. 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. Time in Grade Requirement for GS-15: Applicants who have held a General Schedule (GS) position within the last 52 weeks must have 52 weeks of Federal service at the next lower grade or equivalent (GS-14).
The Senior Counsel serves as a legal expert on matters under the jurisdiction of the Office of the Associate Chief Counsel (International) (INTL), acting as consultant to the Branch Chief and other branch managers, and the Associate and Deputy Associate Chief Counsels. INTL's responsibilities include legal issues arising out of taxation of U.S. persons with foreign activities (foreign tax credits; taxation of income earned through direct or passive investments, controlled and non-controlled foreign corporations, passive foreign investment companies, unincorporated branch operations and foreign partnerships or trusts; and information reporting obligations), the taxation of foreign persons with U.S. activities (effectively connected income, branch profits tax, determination of U.S. residence and consequences of expatriation, withholding of tax on U.S. source income, the taxation of foreign governments and international organizations and their employees), U.S. taxation relating to U.S. territories, and laws relating to cross-border activities of both domestic and foreign persons (transfer pricing; entity classification; cross-border reorganizations; the source of income and allocation of deductions); taxation of financial products and income from international financial services and insurance activities; foreign currency transactions; international information exchange and summons enforcement; conflict of laws and the application of income tax treaties and international agreements. INTL has seven branches, each with expertise in and subject matter jurisdiction over one or more of the above areas. As a General Attorney (Tax) - Senior Counsel for one of INTL's seven branches, you will have the following responsibilities in your assigned branch: Perform technical review of some of the office's most complex, important or novel case/project assignments, particularly those with broad or potentially controversial ramifications. Independently plan, develop, and complete complex legal work products without review, and provides technical guidance and review of other staff work products. Serve as team leader on large-scale INTL guidance and publication projects that may include representatives from other Counsel Divisions or IRS offices. Direct and coordinate work of other team members and oversees all related administrative and logistical matters. Research complex issues and trends affecting INTL legal services and determines likely legal ramifications on INTL programs. Ensure the legal or administrative consequences of potential actions to handle these issues are fully considered and write decision papers to determine Counsel's position on these matters. Prepare final comments/recommendations on behalf of the office. Identify the need for, develop and draft new procedures and regulations to implement, new or amended legislation to ensure that policies are consistent with the intent of the law and are administratively sound and economical in operation and to enable INTL to effectively meet its mission. This is not an all-inclusive list.