Competent Authority Analyst
2 weeks ago
A description of the business units can be found at:
Vacancies will be filled in the following specialty areas:
Large Business and International Director Treaty and Transfer Pricing Operations, APMA, TAIT
WHAT DOES A COMPETENT AUTHORITY ANALYST (TAX TREATY) DO?
The position seeks a tax professional for the Treaty Assistance and Interpretation Team (TAIT) within the office of the Treaty and Transfer Pricing Operations (TTPO), under the direction of the Director, Advance Pricing and Mutual Agreement, Large Business and International Division.
The following are the duties of this position at the full working level.
If this vacancy includes more than one grade and you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and receive training to help you grow in this position.
Receives and reviews taxpayer requests for assistance in obtaining relief from double taxation including, forexample, requests for relief under treaty provisions concerning residency, limitations of benefits, artists,athletes and entertainers, withholding, and all issues other than those involving transfer pricing and relatedallocation of business profits provisions, to determine if such requests comply with procedural guidelines.
Performs a balanced and critical analysis of taxpayer and treaty-partner proposals and performs due diligenceto ensure that the facts and circumstances of the taxpayer's case are sufficiently understood and known toarrive at a legally-supportable and well-reasoned determination.
Evaluates, analyzes, and develops the positions of the United States with respect to complex tax treatyinterpretation and assistance issues and other international tax issues, with minimal direct supervision.
Conducts independent research and analysis of tax, accounting, treaty, and economic issues and coordinateswith IRS subject-matter experts, when necessary.
Prepares positions and other memoranda for the U.S.Competent Authority, recommending a course of actionbased on analysis of the facts of the case, applicable tax law and treaty provisions, and the position of theforeign country.
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