Tax Law Specialist- 12 Month Roster

Duties

WHAT IS THE LARGE BUSINESS AND INTERNATIONALDIVISION?

A description of the business units can be found at: https://www.jobs.irs.gov/about/who/business-divisions

Vacancies will be filled in the following specialty areas:

Large Business and International Director Treaty and Trans Pric Ops

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.

• Assists Examination Teams in planning, directing, and coordinating the examination of international transfer-pricing issues. The incumbent serves on a consulting basis for other Examination Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents assigned to a Coordinated Industry or Industry Examination regarding transfer-pricing issues and transactions. The incumbent may also be assigned to work closely with IRS Examination Teams on multiple examinations simultaneously.
• Collaborates and coordinates with Examination Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents to leverage and expand international issue expertise throughout the IRS, and to ensure consistent application and interpretation of international tax law. The incumbent regularly participates in groups focused on international issues including, but not limited to, International Practice Networks (IPNs).
• Participates in long-term projects involving the development of new auditing techniques, work practices, and training programs for Examination Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents. The incumbent develops and conducts training sessions and holds periodic meetings with IRS personnel at national and local office levels to review all matters relating to international transfer-pricing.
• Performs research and analysis of tax issues involving economics, transfer pricing, and valuation related to specific taxpayers or across taxpayers and industries.
• Provides feedback, technical expertise, and recommendations to IRS management and IRS Counsel on transfer-pricing issues. The International Transfer Pricing Specialist identifies and discusses any issues that require technical advice, field service advice, or industry-wide coordination procedures to be followed.

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Requirements

Conditions of Employment

STANDARD POSITION DESCRIPTIONS (SPD):

PD97643

Visit the IRS SPD Library to access the position descriptions.

• If you are in a telework eligible position, you may be directed to temporarily telework on a full-time basis due to COVID 19. Employees must be within a 200-mile radius of their official assigned post-of-duty (POD) while in a telework status. Once normal operations resume, employees may be directed back to the office to perform the duties of their position. Telework eligibility does not guarantee telework; employees must meet and sustain IRS telework eligibility requirements and supervisor's approval to participate in the IRS Telework Program. As a reminder - If you are selected for a position, you are responsible for reporting to your designated POD (location) on the negotiated start date or as directed by management.
• The employment of any candidate, including a current employee or a new hire, selected for this position will be conditional on obtaining and maintaining a High Risk Security Clearance.
• Obtain and use a Government-issued charge card for business-related travel.

Qualifications

Federal experience is not required. The experience may have been gained in the public sector, private sector or Volunteer Service. 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.

You must meet the following requirements by the closing date of this announcement:

SPECIALIZED EXPERIENCE: GS-14 LEVEL: You must have (1) one year of specialized experience at a level of difficulty and responsibility equivalent to the grade 13 level in the Federal service. Specialized experience for this position includes: Experience with application of tax law to transfer pricing projects, transactions, and controversies, including application of the Internal Revenue Code, corresponding Treasury Regulations, tax treaties, Court decisions and the Organization for Economic Cooperation and Development (OECD) Guidelines related to transfer pricing between US and foreign related parties including transfers of tangible and intangible property, high value services, asset valuations, and risk allocation; Applying auditing techniques to multiple, interrelated transfer pricing issues as listed above on large corporate returns. Performing research and analysis of transfer pricing issues; conducting various kinds of audit steps verifying taxpayers' economic structure, business practices and functions; reviewing and analyzing economic, financial, operational and tax data to determine the existence of a potential transfer pricing issue; performing analyses to determine and/or evaluate tax reporting of intercompany transactions; providing technical advice concerning transfer pricing issues on cases; providing advice and recommendations to other examiners within issue networks during workshops and other knowledge sharing forums. Experience preparing and delivering written and oral communications to explain and defend the Government's position related to transfer pricing; holding conferences with taxpayers, their representatives and others to present and discuss transfer pricing positions and analysis; Experience serving, where necessary, as a qualified witness for the government in litigation cases. Experience assisting on competent authority cases or advance pricing agreements; correlative adjustments, set offs, or commensurate with income; and experience with treaty partners such an exchange of Information (EOI), Joint Audit, or International Compliance Assurance Program (ICAP).

AND

MEET TIME IN GRADE (TIG) REQUIREMENT: For positions above the GS-05, applicants must meet applicable time-in-grade requirements to be considered eligible. One year (52 weeks) at the next lower grade level is required to meet the time-in-grade requirements for the grade you are applying for.

AND

TIME AFTER COMPETITIVE APPOINTMENT: By the closing date (or if this is an open continuous announcement, by the cut-off date) specified in this job announcement, current civilian employees must have completed at least 90 days of federal civilian service since their latest non-temporary appointment from a competitive referral certificate, known as time after competitive appointment. For this requirement, a competitive appointment is one where you applied to and were appointed from an announcement open to "All US Citizens".

For more information on qualifications please refer to OPM's Qualifications Standards.

Education

A copy of your transcripts or equivalent documentation is required for positions with an education requirement, or if you are qualifying based on education or a combination of education and experience. An official transcript will be required if you are selected. If the position has specific education requirements and you currently hold, or have previously held, a position in the same job series with the IRS, there is no need to submit a transcript or equivalent at this time. Applicants are encouraged, but are not required, to submit an SF-50 documenting experience in a specific series.

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: 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. Click here for Foreign Education Credentialing instructions.

Additional information

• We may select from this announcement or any other source to fill one or more vacancies. Additional jobs may be filled.
• The salary range indicated in this announcement reflects the minimum locality pay up to maximum locality pay for all duty locations listed. The range will be adjusted for selected duty location. General Schedule locality pay tables may be found under Salaries & Wages.
• This is a bargaining unit position.
• Tour of Duty: Day Shift - Start and stop times between 6:00am and 6:00pm.
• Alternative work schedule, staggered work hours or telework may be available.
• Relocation expenses - No

Please consider each location carefully when applying. If you are selected for a position at one of your location selections, that location will become your official post of duty.

If the position(s) are no longer needed prior to the closing date, this announcement may be closed early.

This is an open continuous announcement which will be used to fill vacancies in the locations listed as they become available for the next 12 months contingent upon funding and space requirements. Applicants must apply and/or update their applications by 11:59 pm ET at the close of the following cutoff dates to be considered: Cutoff date(s): 01/13/2023, 04/13/2023, 07/13/2023, and 10/13/2023. This announcement may be amended to include additional cut-off dates within the 12-month period if needed, not later than 10 days prior to the additional cut-off date(s). Eligible applicants who apply by the initial cut-off date, will be referred in score order. If additional vacancies exist, remaining applicants will be considered in score order as needed. Selections from this announcement may be made no later than (NLT) 01/16/2023.

WHAT IS THE TRANSFER PRICING PRACTICE? The Transfer Pricing Practice (TPP) primarily focuses on compliance activities for transfer pricing issues and is part of Treaty and Transfer Pricing Operations (TTPO) in the Large Business & International (LB&I) division of the IRS. Transfer pricing involves the pricing of goods, services and intellectual property transferred between related entities of multinational enterprises (typically corporations with a common parent company). When these transactions involve transfers between a U.S. and foreign related entity, tax issues arise over how much income should be reported in each country. The United States and foreign tax administrations have complex tax rules about how to determine intercompany pricing which leads to how much taxable income should be reported in each country. It is an area of significant tax controversy. The IRS Transfer Pricing Practice conducts many types of compliance activities related to transfer pricing including examinations, Compliance Assurance Process (CAP) audits, Campaigns (which may or may not include examinations), assistance with Advance Pricing Agreements and other efforts. Within TPP, there are four field territories (East, North, South and West) as well as the Practice Network. The Transfer Pricing Practice Network supports examiners working on transfer pricing issues by performing risk assessments and identifying emerging issues or issues of strategic importance and develops training and tools for transfer pricing issues, provides advice on campaigns, and assists agents in transfer pricing examinations.

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