General Attorney (Tax)

Description:

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.

Requirements:

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 at the time of referral or by the closing of this announcement, whichever is first:

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-12 Experience Requirements:

1 year of general professional legal experience

GS-13 Experience Requirements:

1 year of general professional legal experience; plus 1 year of professional legal tax experience

GS-14 Experience Requirements:

1 year of general professional legal experience; plus 2 year(s) of professional legal tax experience

Professional Legal Tax Experience is defined as legal work in one of following areas of tax expertise: Corporate; Financial Institutions and Products; Income Tax and Accounting; International; or Passthroughs and Special Industries. 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.

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: Experience working on general 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: Legal tax experience in U.S. international tax matters. Such experience should involve experience in providing regulatory and other technical guidance and legal advice on a variety of international tax issues pertaining to cross-border transactions and activities, such as 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, 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.

Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience.

Education Substitution: An LL.M. degree in the field of this position (i.e. 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.