General Attorney
1 month ago
The principal subject matter areas of the branch include all transfer pricing issues and related regimes and penalties, e-commerce, the section 250 deduction for foreign derived intangible income and global intangible low-taxed income, certain sourcing provisions, and advice to the APMA Program and Treaty and Transfer Pricing Operations.
The Senior Technical Reviewer (STR) serves as a technical expert with respect to the tax areas relating to the functions of Branch 6.
In addition, the STR is responsible for the assignment and review of the cases for some of the attorneys within the Branch; and, as assigned, may perform other administrative/management tasks within the Branch.
The Senior Technical Reviewer in this position functions as an Assistant to the Branch Chief.As a General Attorney (Tax) - Senior Technical Reviewer, you will:
Act as a legal and technical consultant to the Branch Chief, the Deputies Associate Chief Counsel (International), the Associate Chief Counsel (International), and, as assigned, to other officials in the Office of Chief Counsel on some of the most important professional legal and policy matters concerned with the work of the Branch, or that may affect the work of other Branches of the office, or other components of the Office of Chief Counsel.
Such matters involve research on complicated legal problems and the development of recommendations regarding the positions to be taken by the Branch and the Office.
Act as a reviewer and, in some cases as the initiating attorney, on projects involving the development and drafting of Internal Revenue legislation and regulations, considering recommendations for enactment of legislation and the promulgation of regulations, and the issuance of private letter rulings, revenue rulings, technical advice memoranda, general legal advice memoranda, and other guidance.
Act as the principal attorney in charge of recommending the policies and developing the procedures and regulations implementing new or amended legislation for specific areas of tax law and is responsible for ensuring that these policies, procedures, and regulations are consistent with the intent of the law and are administratively sound, efficient, and economical in operation.
Perform activities in the subject area of the Branch including legal assistance, document review, appellate recommendations, and litigation support.
Many of the issues presented for decision are submitted after extensive consideration in the field and elsewhere.Problems presented cover a broad range of tax law issues requiring interpretation of the Internal Revenue Code, tax regulations, published rulings, court cases, and other technical materials.
Make recommendations on the need for initiating, consolidating, or eliminating programs and projects.Act as project manager, assigns (in consultation with the Branch Chief) work to the attorneys and specialists within the Branch, advises them on the approach to take, reviews work product, and provides the Branch Chief with performance feedback of work performed.
As needed, represent the IRS in conferences with taxpayers and their representatives.In this connection, the STR analyzes the transactions or issues involved in light of the Internal Revenue Code and applicable regulations, examines the data submitted (such as court exhibits and briefs), questions taxpayers or their representatives, and makes a determination or recommendation for the IRS.
As necessary, participate in the resolution of complex technical problems presented by taxpayers or their representatives and give advice on important technical, legal, and policy matters to the Associate Chief Counsel (International), the Deputies Associate Chief Counsel (International), and other Office of Chief Counsel officials.
As appropriate, speak or engage in panel discussions before business and professional groups on technical and legal matters relating to the work of the Branch.
As required, and also in cases in which the Branch Chief is absent, the STR substitutes for the Branch Chief and performs the full range of duties of that position.
In situations where the signature by a higher official is not necessary, may take final action with respect to work prepared in the Branch.
Otherwise, may make decisions for referral to higher levels of review.Perform other duties as assigned by management.
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