Tax Law Specialist - Direct Hire

Company: Internal Revenue Service
Location: Warwick
Posted on: January 19, 2023

Job Description:

Duties

WHAT IS THE LARGE BUSINESS AND INTERNATIONALDIVISION?

A description of the business units can be found at:



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.

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• 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.
  
  
  
  
  Requirements
  Conditions of Employment
  
  
  
  
  

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  • 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.
    
  • 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).
    
    
    
    
    
    Qualifications
    
    Federal experience is not required. The experience may have been gained in the public sector, private sector or One year of experience refers to full-time work; part-timework 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: To be minimally qualified for this position 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, including application of the Internal Revenue Code, corresponding Treasury Regulations, tax treaties, Court decisions and the Organization for Economic Cooperation and Development (OECD) Guidelines to transfers of tangible and intangible property, high value services, and risk allocation; examining or planning multiple, interrelated transfer pricing issues undertaken by large multinational companies; Experience performing research and analysis of transfer pricing issues; conducting various kinds of analyses verifying taxpayers' economic structure, business practices and functions; Experience reviewing and analyzing economic, financial, operational and financial and tax data to determine the existence of a potential transfer pricing issue; performing analyses to determine and/or evaluate the correct reporting of intercompany transactions; Experience providing technical advice concerning transfer pricing issues on cases; providing advice and recommendations to other employees within issue networks or during workshops and other knowledge sharing forums. Experience preparing and delivering written and oral communications to explain and defend transfer pricing positions; Experience holding conferences with key corporate tax and other company officials, representatives, and others to present and discuss transfer pricing positions and analysis; and serving, where necessary, as a qualified witness in litigation cases.
    
    
    
    Positions under this announcement are being filled using a Direct Hire Authority (DHA) and Recruitment Incentive is authorized for eligible, highly qualified applicants. For information on the Recruitment Incentive please reference the Additional Information section of this announcement.
    
    
    
    For more information on qualifications please refer to .
    
    
    
    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 .
    
    
    
    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.
    
    
    
    Additional information
    
    
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    • 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 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.
      
    • Obtain and use a Government-issued charge card for business-related travel.
      
    • 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.
      
    • If this position is designated as hard to fill and you were referred by an IRS employee, the employee may be eligible to receive a bonus for referring you under The Employee Referral Bonus Program (ERBP), recruiting strategy.
      
      This is an open continuous announcement which allows applicants to apply up to the closing date of the announcement, 12/29/2023. 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.
      
      
      
      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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        Benefits
        
        
        
        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.
        
        
        
        
        
        
        
        Required Documents
        
        
        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
        
        
      • Military Spouses (If Applicable) - You MUST submit verification of the marriage to the service member(i.e., a marriage license or other legal documentation verifying marriage) AND (1) a copy of your spouse's active military orders; OR (2) verification of your spouse's 100% service-connected disability (e.g., VA Letter and/or DD-214); OR (3) verification of the service member's death while on active duty (DD-1300/Death Certificate). You are not eligible if you were not married to the veteran at the time of death or have since remarried.
        
      • Current and Former Federal Employees Documentation (If Applicable) - You MUST submit a copy of your most recent SF-50 (Notification of Personnel Action) or equivalent personnel action form which shows your current grade and competitive service status. (The "position occupied" block on the SF-50 reflects "1" and your "tenure" block reflects "1" or "2".) If you are applying for a higher grade, it is recommended to provide an SF-50(s) (or equivalent) which clearly demonstrates you meet the 52-week time-in-grade requirement (e.g., Promotion with an effective date more than one (1) year old, Within-Grade-Increase at the highest grade held).
        
        
        
      • 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.
        
        Please note that if you do not provide all required information, as specified in this announcement, you will not be considered for this position (or may not receive the special consideration for which you may be eligible).
        
        
        
        
        How to Apply
        
        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 12/29/2023 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 12/29/2023.
        
        To preview the Application Questionnaire, please click the following link:
        
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        • 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 12/29/2023.
          
          To update your application, including supporting documentation, at any time during the announcement open period, return to your USAJOBS account (). There you will find a record of your application, the application status, and an option to Update Application. This option will no longer be available once the announcement has closed.
          
          
          
          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: .
          
          
          
          
          
          Agency contact information
          
          
          IRS Memphis External
          
          
          
          Email
          
          
          
          
          
          Address
          
          
          Large Business and International Director Treaty and Trans Pric Ops
          
          1111 Constitution Ave NW
          
          Washington, DC 20224
          
          US
          
          
          
          
          
          
          Next steps
          
          
          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.
          
          
          
          Fair & Transparent
          
          The Federal hiring process is set up to be fair and transparent. Please read the following guidance.
          
          
          
          
          
          
          
          
          
          
          
          
          

Keywords: Internal Revenue Service, Warwick , Tax Law Specialist - Direct Hire, Accounting, Auditing , Warwick, Rhode Island