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WHAT IS THE APPEALS AND LARGE BUSINESS & INTERNATIONAL DIVISION?
A description of the business units can be found at:
Vacancies will be filled in the following specialty areas:
Independent Office of Appeals: C&OS; Collection Appeals; Examination Appeals; and SEP&R. Independent Office of Appeals: C&OS; Collection Appeals; Examination Appeals; and SEP&R.
Large Business and International Director Treaty and Trans Pric Ops-Advance Pricing and Mutual Agreement.
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.
- Holds conferences and negotiates issues with taxpayers/representative to resolve tax disputes in a fair and impartial manner. Taxpayers are often officers of publicly traded companies and representatives are typically from the most prestigious national law and accounting firms.
- Area 9 is a national program made up of four teams located throughout the country. Area 9 has primary responsibility for the largest cases in Appeals, generally Large Corporate Compliance Program Cases (LCC) and Industry Cases (IC) with multiple complex tax issues with over $10 million dollars in dispute. This work is accomplished by the incumbent and a team of several employees. Team members are typically experts in a particular aspect of federal taxation and are often grade 14 Technical Specialists, International Specialists or Appeals Officers.
- Communicates and fosters dialogue with peers, customers and partners. Leads several teams that work cases and coaches individual employees in the accomplishment of team objectives and effective problem-solving.
- Advises and coaches team members regarding their team assignments. Provides appropriate and substantive feedback on team assignments to the team member and his/her immediate manager. This feedback is both written and oral; provided on a timely and ongoing basis; addresses the appropriate critical job elements and aspects; and follows guidelines prescribed by the Chief Appeals, the Director, and the Appeals Area Director as to timing, form and content of the feedback.
- Apprises management of critical or sensitive work related matters. Provides recommendations that are technically authoritative and generally determinative as to actions taken. These include advising on the selection, development, training and tenure of team members; determining the effect of and responsibility for statute expirations; independently recommending resolutions of work related issues involving team members; and delineating the impact on compliance arising from a proposed settlement.
- Reviews Advance Pricing Agreement (APA) requests and taxpayer requests for assistance in obtaining relief from double taxation to determine if such requests comply with procedural guidelines.
- Performs a balanced and critical analysis of taxpayer and treaty partner proposals and performs due diligence to ensure that the facts and circumstances of the taxpayer's case are sufficiently understood to arrive at a legally supportable determination.
- Evaluates, analyzes, and develops the positions of the United States with respect to complex transfer pricing issues and other international tax issues.
- Leads IRS projects to determine the best transfer pricing method and position to adopt in a given case in a timely manner.
- Leads and works cooperatively within teams of IRS employees (notable international examiners, economists, and attorneys) and independently develops facts, issues, analysis, and conclusions as needed. Secures additional information directly from taxpayers or from treaty partners in furtherance of these goals when necessary.
- Telework Eligible Positions: Telework eligible positions do not guarantee telework. Employees must meet and sustain IRS telework eligibility requirements (e.g., reporting at least twice a pay period to your assigned Post of Duty (POD)) and supervisor's approval to participate in the IRS Telework Program. Employees must also be within a 200-mile radius of their official assigned post-of-duty (POD) while in a telework status. 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.
- 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))
- Must successfully complete a background investigation, including a FBI criminal history record check (fingerprint check).
SPECIALIZED EXPERIENCE GS-11: To be minimally qualified for this position you must have at least one year of specialized experience equivalent to the next lower level in the normal line of progression. Specialized experience for this position includes: One (1) year of specialized experience at a level of difficulty and responsibility equivalent to the GS-9 grade level in the Federal service. Experience in applying tax law to resolve tax issues and/or erroneous penalty assessments. Applying current and past Internal Revenue Code and related laws, tax laws, court decisions, and regulations to negotiate tax disputes. Experience researching tax related information from a variety of sources (for example, Internal Revenue Manual, IR Code Regulations, commercial databases, court and revenue rulings). Experience reviewing financial books and records to advise individuals on tax ramifications. Experience applying the hazards of litigation to the facts and circumstances of tax disputes. Providing tax law advice or guidance to taxpayers, clients or employer. Experience applying general business practices and basic accounting and financial analysis techniques to analyze financial information (e.g., analyzing taxpayer transcripts, case files, financial documents and records and other information). Experience in verbal, written, and/or virtual communications, preparing and conducting presentations, briefings, training, etc. regarding tax related issues. Experience mediating/negotiating the resolution of a tax dispute between government and individual/business (i.e. sole proprietors and individuals with business and supplemental income) taxpayers.
OR
You may substitute education for specialized experience as follows: A Ph.D. or equivalent doctoral degree in a field of study such as: law, accounting, business or management, economics, math, and finance or 3 full years of progressively higher-level graduate education leading to a doctoral degree in a field of study such as law, accounting, business or management, economics, math, and finance. One year of graduate education is creditable in accordance with its relationship to a year of full-time study at the school attended.
OR
You may qualify by a combination of experience and education. Options for qualifying based on a combination will be identified in the online questions.
SPECIALIZED EXPERIENCE GS-12: Applicants must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-11 grade level in the Federal service. Specialized experience for this position includes: experience in applying tax law to resolve tax issues and/or erroneous penalty assessments. Applying current and past Internal Revenue Code and related laws, tax laws, court decisions, and regulations to negotiate tax disputes. Experience researching tax related information from a variety of sources (for example, Internal Revenue Manual, IR Code Regulations, commercial databases, court and revenue rulings). Experience reviewing financial books and records to advise individuals and businesses on tax ramifications. Experience applying the hazards of litigation to the facts and circumstances of tax disputes. Experience providing tax law advice or guidance to taxpayers, clients or employer. Experience applying general business practices and standard accounting and financial analysis techniques to analyze financial information (e.g., analyzing taxpayer transcripts, case files, financial documents and records and other information). Experience in verbal, written, and/or virtual communications, preparing and conducting presentations, briefings, training, etc. regarding tax related issues. Experience mediating/negotiating the resolution of a tax dispute between government and individual or business (i.e. sole proprietors and individuals with business and supplemental income, small partnerships and corporations) taxpayers.
SPECIALIZED EXPERIENCE GS-13: Applicants must have 1 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 current and past Internal Revenue Code and related laws, tax laws, court decisions, regulations, accounting principles and practices to analyze accounting documents, books, and records specifically to resolve tax disputes. Experience interpreting 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 tax situations; Experience conducting legal research and applying the law to tax situations; Experience applying the hazards of litigation to the facts and circumstances of tax disputes. Experience providing tax law advice or guidance to taxpayers, clients or employer. Experience in verbal, written, and/or virtual communications, preparing and conducting presentations, public forums, briefings, training, etc. regarding tax related issues. Experience mediating/Negotiating the resolution of tax disputes between government and business or individual taxpayers.
SPECIALIZED EXPERIENCE GS-14: You must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-13 grade level in the Federal service. Specialized experience for this position includes: Experience applying tax law and/or accounting principles, theory and practices to analyze and interpret accounting records or legal issues to resolve tax issues or determine tax liabilities. Experience preparing, examining, interpreting and analyzing financial statements of multiple entities (e.g., corporations, partnerships, estates, trusts) to resolve tax disputes; Experience with General Accepted Accounting Principles (GAAP) process from financial to tax administration. Experience conducting legal research and interpreting 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 tax situations; Experience applying litigation procedures and making judgments involving matters of law particularly as they relate to resolving tax disputes. Experience providing tax law advice or guidance to clients or employer; Experience negotiating the resolution of tax disputes between government and corporate or individual taxpayers. Experience negotiating the resolution of legal tax disputes arising from corporate consolidations, mergers, or estate and gift tax valuation issues.
Qualification continues in Education...
For more information on qualifications please refer to .
QUALIFICATION CONT...
SPECIALIZED EXPERIENCE GS-15: You must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-14 grade level in the Federal service. Specialized experience for this position includes: Experience with accounting principles and legal principles to resolve tax disputes of a corporate and complex nature; Experience applying professional accounting principles, theories and practices (for examples, mergers, acquisitions, consolidations, statistical analysis, transfer pricing agreements, foreign transactions) to analyze and interpret accounting books, records, or systems specifically to determine tax liabilities; Experience interpreting the tax law, applying litigation procedures, and evaluating the meaning of the statutes, regulations, court decisions, congressional intent and other interpretive sources. Experience with tax issues including complex legal issues that arise from tax transactions of mergers, acquisitions, consolidations, statistical analysis, transfer pricing agreements, and foreign transactions; Experience preparing, examining or analyzing corporate business accounting functions to distinguish differences between financial statements generated in accordance with Generally Accepted Accounting Principles (GAAP) and those used for tax reporting purposes; Experience differentiating between the financial characteristics and tax implications of business entities (for example, reorganizations and restructuring) and ensuring entities are classified correctly; Experience in Corporate and Industry tax issues such as: inventory valuation (LIFO,) transfer pricing agreements, corporate investments and revenue recognition, life insurance, property and casualty insurance, reallocation of corporate income; Experience in negotiating the resolution of tax disputes in situations with corporate consolidations, corporate mergers, and corporate foreign transactions.
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 .
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 for Foreign Education Credentialing instructions.
- A 1-year probationary period is required.
- Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
- We may select from this announcement or any other source to fill one or more vacancies. Additional jobs may be filled.
- This is a bargaining and non-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..
- File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on.
Though many locations may be listed, you will be limited to a maximum of 3 location choices. 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.
This is an open continuous announcement which allows applicants to apply up to the closing date of the announcement, 01/19/2024. This announcement will establish an inventory of applicants. Contingent upon funding and space requirements, one or more vacancies may be filled at the locations listed in this announcement as they come available. Cut-off dates: 1st Cut-Off 05/12/2023; 2nd Cut-Off 07/21/2023; 3rd Cut-Off 10/20/2023; 4th Cut-Off 1/18/2024.
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A career with the U.S. government provides employees with a comprehensive benefits package. As a federal employee, you and your family will have access to a range of benefits that are designed to make your federal career very rewarding. .
Eligibility for benefits depends on the type of position you hold and whether your position is full-time, part-time or intermittent. Contact the hiring agency for more information on the specific benefits offered.
The following documents are required and must be provided with your application. All application materials, including transcripts, must be in English.
- Online Application - Questionnaire
- Education - See Education Section above
- Registration/License (If Applicable) - active, current registration/license
- High School Diploma (or equivalent) - If you are 16 or 17 years of age, you MUST submit documentation of graduation from high school (or equivalent); OR completion of a formal vocational training program; OR statement from school authorities agreeing with your decision to pursue employment rather than continuing your education.
This Direct Hire Public Notice is to gather applications that may or may not result in a referral or selection. Your application will remain active through the open period of this Public Notice. Applicants will be referred on a first in, first out basis. Those applicants who are applying earlier in the process will stand a much better chance of being referred for consideration in the selection process.
The following instructions outline our application process. You must complete this application process and submit any required documents by 11:59 p.m. Eastern Time (ET) on 01/19/2024 in this announcement. We are available to assist you during business hours (normally 8:00 a.m. - 4:00 p.m. ET, Monday - Friday). If applying online poses a hardship, please contact us by noon ET on 01/19/2024.
To preview the Application Questionnaire, please click the following link:
- To begin the application process, click the "Apply Online" button.
- You will be re-directed to USA STAFFING to complete your application process; answer the online questions and submit all required documents. (To submit supporting documents, import documents from USAJOBS to the appropriate document types. If the document you need was not imported from USAJOBS, you may upload it directly into this application. To protect your privacy, we suggest you first remove your SSN).
- To complete, you must click the "Submit Application" button prior to 11:59 PM (ET) on 01/19/2024.
To verify the status of your application both during and after the announcement open period, log into your USAJOBS account: . All of your applications will appear on the Welcome page. The application record in your USAJOBS account provides an Additional Application Information page that provides information regarding the documentation you submitted and any correspondence we have sent related to this application. The Application Status will appear along with the date your application was last updated. For information on what each Application Status means, visit: .
Website
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Washington, DC 20224
US
Treasury believes in a working environment that supports inclusion; please view our reasonable accommodation policies and procedures at . We will provide reasonable accommodation to applicants with disabilities on a case-by-case basis; please contact us if you require this for any part of the application and hiring process.
Once your application package and online questionnaire is received you will receive an acknowledgement email. You are responsible for checking status updates and notifications in USAJOBS. Hard copy notifications will not be sent to you. You may check the status of your application for this position at any time by logging onto the USAJOBS "My Account" tab and clicking on "Application Status." For a more detailed update of your application status, you may click on "more information." Please notify us if your contact information changes after the closing date of the announcement. If your email mailbox is full or blocked (SPAM) you may not receive important communication that could affect your consideration for this position.
The Federal hiring process is set up to be fair and transparent. Please read the following guidance.