Job Title

General Attorney (Tax)

Duties

The Office of Associate Chief Counsel (International) responsibilities 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. As a General Attorney (Tax), you will:

• Serve as the legal and technical consultant to the Associate Chief Counsel (International) and the Deputies Associate Chief Counsel (International); and provide legal support to the Office of the Commissioner of the Internal Revenue Service, particularly the Large Business & International (LB&I) Division. Provide legal advice, both written and oral, on matters relating to the tax consequences of transactions and activities that cross the borders of the United States.
• Provide legal assistance and advice on application of the international provisions of U.S. revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party, and foreign revenue laws that pertain to or affect tax matters in the United States.
• Provide legal assistance and support to Division Counsel pertaining to the defense or settlement of international tax cases pending in the U.S. Tax Court; and in coordination with Division Counsel, review pleadings, motions, pre-trial filings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with the litigation.
• Provide legal assistance on the substantive review of technical guidance, working closely with those drafting regulations, revenue rulings, revenue procedures, announcements, notices, and news releases. Provide legal assistance to IRS examiners on international tax issues and coordinate the processing and review of non-docketed cases submitted to Associate Chief Counsel (International) for consideration.
• Provide legal advice and assistance to the United States Competent Authority on matters of treaty interpretation and implementation, including both substantive and complex legal issues as well as all procedural issues arising out of treaty-based processes, such as information exchange and cross-border information gathering processes.

This is not an all-inclusive list. If selected at a lower grade level, you will have the opportunity to learn to perform the duties of the position and will receive training to help you grow in the position.