Multiple Locations3 days ago
Click to learn more: IRS Office of Chief Counsel Careers Site Meet Our People Learn about our Legal Divisions The responsibilities of the Associate Office of Chief Counsel, International, include legal issues arising out of taxation of U.S. persons with foreign activities (foreign tax credits; taxation of income earned through direct or passive investments, controlled and non-controlled foreign corporations, passive foreign investment companies, unincorporated branch operations and foreign partnerships or trusts; and information reporting obligations), the taxation of foreign persons with U.S. activities (effectively connected income, branch profits tax, determination of U.S. residence and consequences of expatriation, withholding of tax on U.S. source income, the taxation of foreign governments and international organizations and their employees), U.S. taxation relating to U.S. territories, and laws relating to cross-border activities of both domestic and foreign persons (transfer pricing; entity classification; cross-border reorganizations; the source of income and allocation of deductions); taxation of financial products and income from international financial services and insurance activities ; foreign currency transactions; international information exchange and summons enforcement; conflict of laws and the application of income tax treaties and international agreements. 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 development, interpretation, and administration of the international tax provisions of the Internal Revenue Code, including experience in one or more of the following areas: tax treaties, international tax rules affecting individuals, and withholding taxes anti-deferral provisions, such as subpart F, the NCTI regime, and passive foreign investment companies foreign tax credits and sourcing of income cross-border mergers and acquisitions and international tax aspects of partnerships international tax issues related to banking, financial products, and insurance transfer pricing and FDDEI exchange of information, other information gathering, and issues related to territories 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).