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 agency
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:
- Draft published guidance, including regulations, revenue rulings, revenue procedures, etc.
- Provide written legal advice to taxpayers and field components of the IRS.
- Make recommendations regarding litigation; review briefs and other litigation-related documents.
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 June 22, 2020 to December 31st, 2020. Lists will be issued based on the following cut-off dates and as vacancies occur, whichever is first:
- August 31, 2020
- October 30, 2020
- December 31, 2020
Cutoff for receipt of applications will be midnight EST on the cutoff date. 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.
Occasional travel – Limited travel may be required.
Conditions of Employment
- Please refer to "Conditions of Employment".
- Click "Print Preview" to review the entire announcement before applying.
CONDITIONS OF EMPLOYMENT:
- A one-year trial period is required.
- Must successfully complete a background investigation.
- 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, please 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.
- Obtain and use a Government-issued charge card for business-related travel.
- 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 two years of returns.
- Because of its tax-related mission, the Office of Chief Counsel requires fingerprinting, tax verification, and a background security investigation as part of the pre-employment process.
You must meet the following requirements by the cut-off dates of this announcement:
- Possess a J.D. and three years of professional attorney experience – one year of general legal attorney experience plus two years of legal tax experience (comparable to the GS-13 level in the Federal service).
- Possess an LL.M. degree and two years of legal tax experience (comparable to the GS-13 level in the Federal service).
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 providing legal advice and litigation support on tax matters involving recognition and timing of income and deductions of individuals and corporations, sales and exchanges, capital gains and losses, accounting methods and periods, installment sales, long-term contracts, inventories and alternative minimum tax to the Internal Revenue Service, the Office of Chief Counsel, the Department of the Treasury, or to other government agencies and the public.
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 have included working on one or more of the following areas: 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: 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:
- The J.D. and/or LL.M. must be from an ABA-accredited law school.
- Candidates must be admitted to practice law before the highest court of a state or territory of the United States; the District of Columbia; or the Commonwealth of Puerto Rico.
- One year of professional legal experience refers to full-time work after admittance to the bar. Part-time work is considered on a prorated basis.
- The professional legal experience may have been gained in either the public or private sector.
- To ensure full credit for your work experience, please indicate on your resume the dates of employment by month/year, as well as the number of hours worked per week.
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.
- We may select from this announcement or any other source to fill one or more vacancies.
- Relocation expenses are not authorized.
- This is a bargaining unit position.
- We offer opportunities for telework and flexible work schedules.
How You Will Be Evaluated
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.
To preview questions please click here .
Background checks and security clearance
Drug test required
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.