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Tax Attorney Advisor

1 month ago

Chicago, Illinois, United States Internal Revenue Service Full time
Job Summary

The Internal Revenue Service (IRS) is seeking a highly skilled and experienced Tax Attorney Advisor to join its team as a Special Counsel. This role will support the Deputy Associate Chief Counsel (Controversy & Litigation) and the Associate Chief Counsel (International) in all matters involving controversy and litigation, including maintaining close working relationships with other Chief Counsel Divisions, the IRS Divisions, and the Department of Justice.

Key Responsibilities
  • Provide technical guidance to the IRS, other Chief Counsel Divisions, and the DOJ to support the enforcement of tax laws involving cross-border transactions and activities.
  • Work closely with the branches within International (which are comprised of groups of attorneys specializing in particular areas of international tax).
  • Draft both legal and non-legal documents ranging from tax advocacy designed for legal practitioners to non-technical/educational materials targeted for more general use.
  • Provide oral and written advice applying the tax laws related to cross-border transactions and activities, including the international provisions of the U.S. revenue laws, and bilateral and multilateral tax treaties and agreements to which the United States is a party.
  • Exercise decision-making skills, including in case or project management.
  • Analyze and interpret complex tax legislation, regulations, and policy matters that impact international tax policies and guidance.
  • Operate as a critical link between subject matter experts in the International office and other Counsel offices, as well as personnel in Appeals and Examination, with respect to the preparation of technical guidance, international field service, litigation, and strategic programs.
  • Ensure that controversies stemming from cross-border transactions and activities are developed and handled consistently with the correct interpretation of international provisions of the U.S. revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party, and all foreign revenue laws that pertain to or affect tax matters in the United States.
  • Render legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning international issues under examination in the audit of returns or in the consideration of claims for refunds or in respect of matters of treaty interpretation; and participate in the preparation of briefs and other materials in connection with U.S. Tax Court litigation involving international matters.
  • Prepare or review recommendations concerning the defense, settlement, concession, or appeal of refund suits pending in international cases in the U.S. District Courts or the U.S. Court of Federal Claims; and work with the Department of Justice in connection with preparation of briefs and positions and strategy taken in international appellate litigation.
Requirements
  • Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association.
  • Applicants must be an active member in good standing of the bar of a State, U.S. Commonwealth, U.S. territory, the District of Columbia, or the Commonwealth of Puerto Rico.
  • GS-15 Experience Requirements: 1 year of general professional legal experience from any area of expertise; plus 3 year(s) of professional legal tax experience.
Preferred Qualifications
  • LL.M. degree in the field of tax may be substituted for the one year of the general legal experience listed above.
How to Apply

To apply, please submit a resume, vacancy question responses, and any required documents. An unofficial or official transcript(s) for your J.D. degree or LL.M. degree, an 8-10 page legal writing sample, and a memorandum of interest summarizing your interest in the position are required. Current Chief Counsel Employees are also required to submit a copy of your most recent, signed, completed annual performance appraisal and a Supervisory Report for Non-Supervisory Positions (Senior Counsel Only) regarding your suitability for the position as completed by your current supervisor.