Associate Chief Counsel

4 days ago

Washington, United States Internal Revenue Service Full time

As a key member of the executive staff of the Chief Counsel, the Associate Chief Counsel (Partnerships, S corporations, Trusts, and Estates) is responsible for coordinating and directing all activities of the Associate Office for Partnerships, S corporations, Trusts, and Estates and Gifts, within the Office of Chief Counsel, Internal Revenue Service (IRS).

The Associate Office of Partnerships, S corporations, Trusts, and Estates (Office) is comprised of approximately fifty attorneys, tax law specialists, and support employees in Washington, D.C.; and provides legal advisory services that support the uniform interpretation, application, enforcement, and litigation of tax laws involving a wide range of business and investment entities, including partnerships, S corporations, trusts, and estates (passthrough entities and certain transfer taxes - referred to below collectively as "transfer taxes").

The Office manages the classification of domestic and foreign entities and issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift, and generation skipping taxes and with Treasury officials and IRS Division Commissioners and other Associate and Division Counsel on program matters, such as identifying and prioritizing emerging issues and publishing guidance.

MAJOR DUTIES AND RESPONSIBILITIES:

Major duties include but are not limited to:
Serves as the principal legal advisor to the IRS and the Office of Chief Counsel on matters relating to passthrough entities and transfer taxes, publishes public and other technical guidance on such issues, and shares responsibility with the Division Counsel for the direction and oversight of the Counsel-wide litigation program involving passthrough entities and transfer taxes. Represents the IRS and Treasury on sensitive and controversial issues related to these areas.

Formulates and directs programs and policies with respect to litigation involving passthrough entities and transfer taxes in the U.S. Tax Court. Assures IRS-wide consistency of approach in tax litigation involving passthrough entities and transfer taxes; consults with the Division Counsel as to the defense or settlement of cases pending in U.S. Tax Court (including the preparation and approval of Chief Counsel actions on decisions) and, reviews and coordinates pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S. Tax Court litigation involving passthrough entities and transfer taxes.

Provides executive direction to staff engaged in drafting revenue rulings, revenue procedures, announcements, and news releases to be published for the guidance of taxpayers and IRS personnel; issuing technical advice memoranda responding to questions raised by IRS examiners; issuing private letter rulings and general technical information letters in response to requests from taxpayers; and preparing Chief Counsel Advice and other legal opinions for other Chief Counsel offices and IRS functions with respect to legal questions raised in litigation and IRS programs.

Works with Treasury officials to coordinate recommendations for legislation that particularly affects matters involving passthrough entities and transfer taxes; directs IRS participation in this aspect of the legislative process, including the furnishing of advice and guidance with respect to the development of new or revised legislative proposals; oversees IRS participation with legislative staffs in the drafting of such legislation and committee reports.

Coordinates the processing and review of nondocketed cases submitted for consideration by various local, area, division, or national levels. Renders legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning issues involving passthrough entities and transfer taxes under examination in the audit of returns, or in the consideration of claims for refund. Develops and monitors performance measures and program goals for the provision of legal services and published guidance, and the implementation, compliance, and outreach initiatives on issues involving passthrough entities and transfer taxes.

Plans, directs, and coordinates nationwide programs relating to passthrough entities and transfer taxes, including with respect to all personnel, fiscal and budgetary requests and recommendations. Balances the diverse needs of program segments, and determines the allocation and deployment of human and fiscal resources that best positions the organization to meet the needs of clients as a whole.

Directs and oversees the overall management of the division's legal staff. Ensures all management functions are handled equitably and in a manner that is responsive to the needs of all programs that the division supports. Ensures sound position management policy. Takes positive steps in support of all merit system principles.

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