Location: Miami,FL, USA
The Special Counsel supports the Deputy Associate Chief Counsel (Controversy & Litigation) and the Associate Chief Counsel (International) ( International ) in all matters involving controversy and litigation, including maintaining close working relationships with the other Chief Counsel Divisions, the Internal Revenue Service (IRS) Divisions, and the Department of Justice. International's objectives include advising government stakeholders in all matters involving international tax controversy and litigation, including against regulation challenges and issues of first impression under provisions of the Tax Cuts and Jobs Act, Inflation Reduction Act, and regulations under each, as well as important, newly arising issues under longstanding law, such as transfer pricing, treaty interpretation, and common law doctrines, and the application of the foregoing to aggressive tax planning. International provides technical guidance to the IRS, other Chief Counsel Divisions, and the DOJ to support the enforcement of tax laws involving cross-border transactions and activities. The Special Counsel works closely with the branches within International (which are comprised of groups of attorneys specializing in particular areas of international tax).
As an Attorney-Advisor (Tax) Special Counsel, you will:
This is not an all-inclusive list.
Requirements:
Qualifications:
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.
Basic Requirements for Attorney-Advisor (Tax) Special Counsel:
GS-15 Experience Requirements:
Professional Legal Tax Experience is defined as: Litigation and controversy experience involving the taxation of cross-border transactions and activities in proceedings before IRS Exam, IRS Independent Office of Appeals, and/or in the U.S. Tax Court, the U.S. Court of Federal Claims, the United States District Courts, and/or the U.S. Courts of Appeals. 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) 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 the number of hours worked per week, on your resume.
Education Documentation: 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.
Required Documents: 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).
How to Apply: 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) on the closing date. We are available to assist you during business hours (normally 7:30 AM to 4:00 PM ET, Monday - Friday).
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