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Appeals Officer

2 months ago

New Orleans, United States Internal Revenue Service Full time

Duties

Performs analysis and conducts Appeals conferences for the resolution and settlement of international tax issues under the jurisdiction of the Independent Office of Appeals. Cases assigned at this level are characterized by a lack of clearly applicable precedents/procedures regarding issues that are either novel, complex, or involve different possible interpretations of fact and law. Determines tax treatment of foreign tax credits, taxable income and income exclusion for U.S. Taxpayers living abroad or doing business in foreign jurisdictions. Determines the same for foreign taxpayers doing business and earning income in the United States. Determines assessment and abatement of international penalties and Title 31 penalties. Receives and works cases and issues which have been referred by Appeals management when the tax issues warrant the services of an International Specialist. Serves as an expert in determining a final settlement and resolving appealed cases that involve international tax issues with difficult legal or factual questions where precedents are unavailable or not clearly applicable and there are large sums of money involved. Reviews international case files, supporting documents, and other information germane to the determination of tax liability. Analyzes case files to determine issues of fact and law. Reconciles apparent factual discrepancies by further investigation, reconstruction, and/or the determination of the interpretation most consistent with all available evidence. Requirements

Must be a U.S. Citizen or National and provide proof of U.S. Citizenship. (Birth certificate showing birth in the U.S; Unexpired U.S. Passport; Certificate of Citizenship or Naturalization; or Report of Birth Abroad of a U.S. Citizen (Form FS-240)) Qualifications

SPECIALIZED EXPERIENCE GS-13: You must have at least one year of specialized experience at a level of difficulty and responsibility equivalent to the GS-12 grade level in the Federal service. Specialized experience for this position includes: Experience in applying tax law or accounting principles to resolve tax issues. Applying professional accounting and legal principles, theory, and practices to analyze and interpret accounting books, records, systems and/or legal issues, specifically to determine effect on tax liabilities or financial statements; Conduct research and interpret the law in situations where there are uncertainties or conflicts in statutes, regulations, case law, precedence or other guidance to determine and apply the appropriate intent of the law in international tax situations; Experience analyzing and/or applying litigation procedures and making judgments involving matters of law particularly as they relate to resolving international tax disputes; Assessing the hazards of litigation by interpreting and applying accounting and legal principles to the facts and circumstances of international tax disputes; Providing international tax law advice or guidance to internal or external stakeholders; Experience participating in a resolution of tax disputes between government and corporate or individual taxpayers. Preparing memorandums, presentations and briefings of complex international tax law issues. Federal experience is not required. The experience may have been gained in the public sector, private sector or

One year of experience refers to full-time work; part-timework is considered on a prorated basis. To ensure full credit for your work experience, please indicate dates of employment by month/year, and indicate number of hours worked per week, on your resume. Education

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. FOREIGN EDUCATION: Education completed in foreign colleges or universities may be used to meet the requirements. You must show proof the education credentials have been deemed to be at least equivalent to that gained in conventional U.S. education program. It is your responsibility to provide such evidence when applying.

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