USA
10 days ago
General Attorney (Tax) - Senior Counsel (Employment Taxes)
Summary Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. Please click "Learn more about this agency" to find out more about Chief Counsel's various offices, to view some of the workplace attributes that Chief Counsel's workforce rates most favorably, and to hear from employees themselves. Responsibilities The Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) provides published guidance, field support and taxpayer advice on tax matters involving employee plans, exempt organizations, employment taxes, executive compensation, health and welfare benefits, and certain federal, state, local and Indian tribal government issues to a wide variety of internal and external customers. As a General Attorney (Tax) Senior Counsel, you will serve: As a legal expert on matters under the jurisdiction of the Office of the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) (EEE), acting as consultant to the Branch Chief (Employment Tax), the Deputy Associate Chief Counsel, and the Associate Chief Counsel on issues focusing on employment taxes and certain fringe benefit provisions. Assignments include: Serving as Senior Counsel with responsibility for handling and performing technical review of some of the office's most complex, important, or novel case and project assignments, particularly those with broad, or potentially controversial ramifications. You will provide expert advice and litigation support services on complicated tax matters involving employment taxes to a wide variety of internal and external customers and clients. As delegated by the branch chief or executives, you will independently plan, develop and complete complex legal work products without review, and provide technical guidance and review of work products produced by other staff. You will ensure such products are technically complete and adhere to office policy, while exercising signature authority in accordance with delegated authority. You will apply a high level of sophisticated analysis and research to identify and assess approaches to make recommendations on behalf of the Office to program executives and managers. As appropriate, you will interact with personnel from other Counsel offices, IRS, Treasury, other federal agencies, and outside parties on behalf of EEE to exchange information or coordinate actions in the handling and completion of assignments. Serving as team leader on large-scale EEE guidance and publication projects that may include representatives from other Counsel or IRS offices. You will direct and coordinate work of other team members and oversees related administrative and logistical matters. Developing procedural guidelines in conjunction with the review of complex advisory opinions, private letter rulings, closing agreements, Chief Counsel Advice, technical advice, revenue rulings, revenue procedures, notices, announcements, briefs, defense letters, affirmative suit letters, settlement letters, and other technical materials for publication, to assist EEE attorneys in the development and issuance of office products. Researching complex issues and trends affecting EEE legal services and determines the likely legal ramifications on EEE programs. You will ensure that the legal or administrative consequences of potential actions to handle these issues are fully considered and write decision papers to determine Counsel's position on these matters. Decision papers can serve as future guidelines in the handling of these legal issues; and Serving as a primary reviewer on proposed legislation with potential impact on EEE programs and prepare final comments and recommendations on behalf of the Office. You will identify the need for and develop and draft new procedures and regulations to implement new or amended legislation to ensure that policies are consistent with the intent of the law, administratively sound and economical in operation, and to enable EEE to effectively achieve its mission. This is not an all-inclusive list. Requirements Conditions of Employment Qualifications In order to qualify, you must meet the education and/or experience requirements detailed below by the closing date of this announcement. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application. To qualify for this position of General Attorney (Tax) Senior Counsel you must meet the qualification requirements listed below by the closing of this announcement: Basic Requirements for General Attorney (Tax) Senior Counsel: Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; AND 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 Professional Legal Tax Experience is defined as: Knowledge and expertise of the following Code sections: 61 - fringe benefit valuation rules; 74(c) - employee achievement awards; 107 - parsonage allowance; 102(c) - employee gifts; 117(c) - scholarship limitation; 119 - meals and lodging; 132 - certain fringe benefits; 1401 through 1403 - self-employment tax; 3101 through 3134 - Federal Insurance Contributions Act (FICA) tax, including worker classification; 3201 through 3241 Railroad Retirement Tax Act (RRTA) tax; 3301 through 3311 - Federal Unemployment Tax Act (FUTA) tax; 3401 through 3404 - federal income tax withholding, including statutory employer rule; 3501 through 3512 - general employment tax provisions, including agents and Certified professional employer organizations; Miscellaneous Subtitle F provisions - employment tax reporting, refund and adjustment procedures; 7436 - Tax Court proceedings for determinations of employment status; Section 530 of the Revenue Act of 1978; employment tax credits provided under the Families First Coronavirus Response Act (FFCRA), Coronavirus Aid, Relief, and Economic Security (CARES) Act, and American Rescue Plan Act of 2021 (ARP). At least one year of this experience must be equivalent to the work performed at the next lower grade/level position in the federal service (GS-14). Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience. Education Substitution: An LL.M. degree in the field of the position (tax) may be substituted for the one year of the general legal experience listed above. Experience refers to paid and unpaid experience, including volunteer work done through National Service programs (e.g., Peace Corps, AmeriCorps) and other organizations (e.g., professional; philanthropic; religious; spiritual; community; student; social). You will receive credit for all qualifying experience, including volunteer experience. One year of experience refers to full-time work; part-time work 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. Time in Grade Requirement for GS-15: Applicants who have held a General Schedule (GS) position within the last 52 weeks must have 52 weeks of Federal service at the next lower grade or equivalent (GS-14). 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. A college or university degree generally must be from an accredited (or pre-accredited) college or university recognized by the U.S. Department of Education. For a list of schools which meet these criteria, please refer to Department of Education Accreditation page. FOREIGN EDUCATION: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. For further information, visit: Recognition of Foreign Qualifications | International Affairs Office (ed.gov). Additional Information We may select from this announcement or any other source to fill one or more vacancies. Relocation expenses are not authorized. This is a bargaining unit position. We offer opportunities for telework. We offer opportunities for flexible work schedules. The salary range indicated in this announcement covers multiple locality areas. Your salary will be adjusted based on the post of duty for which you are selected. Conditions of Employment Continued: Subject to a 1-year trial period (unless already completed). Complete a Declaration for Federal Employment to determine your suitability for Federal employment, at the time requested by the agency. If you are a male applicant born after December 31, 1959, certify that you have registered with the Selective Service System or are exempt from having to do so. Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer. Obtain and use a Government-issued charge card for business-related travel. File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on. Undergo an income tax verification. The employment of any candidate, including a current employee or a new hire, selected for this position may be conditional upon classification and/or audit of federal tax returns. This audit may include up to 2 years of returns. This position requires that the successful candidate undergo personnel vetting, which includes a background investigation and enrollment upon onboarding into "Continuous Vetting." Enrollment in Continuous Vetting will result in automated record checks being conducted throughout one's employment with Treasury. The successful candidate will also be enrolled into FBI's Rap Back service, which will allow Treasury to receive notification from the FBI of criminal matters (e.g., arrests, charges, convictions) involving enrolled individuals in near real-time. There are three key documents that contain important information about your rights and obligations. Please read and retain these documents: Noncriminal Justice Applicant's Privacy Rights, for those who undergo an FBI fingerprint-based criminal history record check for personnel vetting, which includes Rap Back, FD-258 Privacy Act Statement - FBI (this is the same statement used when your fingerprints are submitted as part of your background investigation), and SEAD-3-Reporting-U.pdf (dni.gov), (applicable to those who hold a sensitive position or have eligibility for access to classified information)"
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