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Summary

Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. Please click "Learn more about this agency" to find out more about Chief Counsel's various offices, to view some of the workplace attributes that Chief Counsel's workforce rates most favorably, and to hear from employees themselves.

Duties

As a General Attorney (Tax), you will handle all aspects related to professional legal work involving one or more of the following areas:

Qualified Retirement Plans - 401-436 - rules for qualified retirement plans; 403(b) - certain employee annuity plans; 408 and 408A - individual retirement arrangements (IRAs) and Roth IRAs; 457(b) - certain eligible deferred compensation plans; 414(d) - governmental plans; 414(e) church plans; 501(a) - exemption from tax for qualified retirement plan trusts; 72 - taxation of distributions from qualified retirement plans; 3405 - withholding rules for designated distributions from retirement arrangements; 4971, 4972, 4980, 4980F - penalties and excise taxes related to qualified retirement plan failures.
Executive Compensation Arrangements - 83 - property transferred in connection with the performance of service; 162(m) - deduction limit on excess compensation; 280G and 4999 - golden parachute payments; 402(b) - nonexempt employees trust/secular trust; 403(c) - non-qualified annuities or annuities purchased by exempt organizations; 404(a)(5) - deduction for nonqualified deferred compensation; 409A - nonqualified deferred compensation; 421 through 424 - statutory stock options; 451 - constructive receipt (as applied to compensation arrangements); 457(f) - tax treatment of participants in ineligible deferred compensation plans of state and local governments and tax-exempt entities; 457A - nonqualified deferred compensation from certain tax indifferent parties, and 4960 - excise tax on tax-exempt organization executive compensation.
Health and Welfare Benefits - 79 - group term life insurance; 104 - compensation for injuries and sickness (except 104(a)(2)); 105 - accident and health plans; 106 -employer provided coverage under accident or health plans; 125 - cafeteria plans; 129 -dependent care assistance programs; 223 - health savings accounts; 419 and 419A - funded welfare benefit plans; 501(c)(9) - voluntary employees' beneficiary associations (VEBAs); 4980B - continuation coverage requirements of group health plans (COBRA); 4980H - employer shared responsibility provisions; 9801 through 9833 -HIPAA and related health care benefit provisions.
Employment Tax - 61 - fringe benefit valuation rules; 74(c) - employee achievement awards; 107 - parsonage allowance; 102(c) - employee gifts; 117(c) - scholarship limitation; 119 - meals and lodging; 132 - certain fringe benefits; 1401 through 1403 - self-employment tax; 3101 through 3134 - Federal Insurance Contributions Act (FICA) tax, including worker classification; 3201 through 3241 Railroad Retirement Tax Act (RRTA) tax; 3301 through 3311 - Federal Unemployment Tax Act (FUTA) tax; 3401 through 3404 - federal income tax withholding, including statutory employer rule; 3501 through 3512 - general employment tax provisions, including agents and Certified professional employer organizations; Miscellaneous Subtitle F provisions - employment tax reporting, refund and adjustment procedures; 7436 - Tax Court proceedings for determinations of employment status; Section 530 of the Revenue Act of 1978; employment tax credits provided under the Families First Coronavirus Response Act (FFCRA) and Coronavirus Aid, Relief, and Economic Security (CARES) Act.
Exempt Organizations - 115 - income of states, municipalities, etc.; 501 through 509 - requirements of tax-exempt status under 501(a) and related provisions and foundation classification, where applicable; 511 through 514 - unrelated business income tax; 527 - political organizations; 529 - qualified tuition programs; 529A qualified ABLE programs; 530 - Coverdell education savings accounts; 4911 and 4912 - excise taxes on public charities; 4940 through 4948 - excise taxes on private foundations; 4958 through 4968 - excise taxes on excess benefit transactions, hospital compliance failures, donor advised funds, excess compensation, and certain investment income; 6033 - exempt organization reporting requirements; 6104 - disclosure of certain exempt organization information; 7428 - declaratory judgments related to section 501(c) organizations; 7611 - restrictions on church tax inquiries and examinations; and application of Federal tax laws to Indian tribal governments and their distributions.

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.

Requirements

Conditions of Employment

Refer to "Additional Information"
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Must be a U.S. Citizen or National

Qualifications

In order to qualify, you must meet the education and/or experience requirements detailed below by the closing date of this announcement. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.

To qualify for this position of General Attorney (Tax) you must meet the qualification requirements listed below by the closing of this announcement:

Basic Requirements for General Attorney (Tax):

Possess at least the first professional law degree (LL.B. 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-12 Experience Requirements:

1 year of general professional legal experience from any area of expertise

GS-13 Experience Requirements:

1 year of general professional legal experience from any area of expertise; plus
1 year of professional legal tax experience

GS-14 Experience Requirements:

1 year of general professional legal experience from any area of expertise; plus
2 years of professional legal tax experience

Professional Legal Tax Experience is defined as: Experience handling sophisticated legal issues and interpretations relating to one or more of the following areas: qualified retirement plans, executive compensation, health and welfare benefits, exempt organizations, or federal employment taxes and/or fringe benefits.

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.

Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience.

Education Substitution: An LL.M. degree in the field of the position (tax) may be substituted for the one year of the general legal experience listed above.

Experience refers to paid and unpaid experience, including volunteer work done through National Service programs (e.g., Peace Corps, AmeriCorps) and other organizations (e.g., professional; philanthropic; religious; spiritual; community; student; social). You will receive credit for all qualifying experience, including volunteer experience. 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.

How You Will Be Evaluated

You will be evaluated for this job based on how well you meet the qualifications above.

Applicants will be considered based on their overall background as it relates to the position to be filled. Interviews may be held at the option of the office. All application materials and interviews, if conducted, will be used in the final evaluation and selection process.

Referral: Professional Order will be used to refer and select eligible candidates. Veterans' preference is applied after applicants are assessed. Preference eligibles will be listed at the top of the certificate in alphabetical order and considered before non-preference eligibles. All other candidates will be listed in alphabetical order. If you are among the top qualified candidates, you may be required to participate in a selection interview. We will not reimburse costs related to the interview, such as travel to and from the interview site.

Bargaining Unit Chief Counsel employees will be given first consideration. To receive first consideration, Bargaining Unit Chief Counsel employees seeking reassignment must be on the Master First Consideration List (MFCL). In regard to this announcement, the MFCL is only for reassignments of employees currently occupying Bargaining Unit positions. If you are applying for a promotion, please apply to the announcement.

Required Documents

A complete application includes 1. A resume, 2. Vacancy question responses, and 3. Submission of any required documents. Please note that if you do not provide all required information, as specified in this announcement, you may not be considered for this position (or may not receive the special consideration for which you may be eligible).

All applicants are required to submit a resume either by creating one in USAJOBS or uploading one of their own choosing. (Cover letters are optional.) To receive full credit for relevant experience, please list the month/year and number of hours worked for experience listed on your resume. We suggest that you preview the online questions, as you may need to customize your resume to ensure that it supports your responses to these questions. Please view .

In addition, applicants are required to submit:

An unofficial or official transcript(s) for your J.D. degree or LL.M. degree (an official transcript is required if you are selected)
A 4-5 page legal writing sample
A memorandum of interest summarizing your interest in the position

Current Chief Counsel Employees are also required to submit:

A copy of your most recent, signed, completed annual performance appraisal which includes the final rating. If it is not dated within the last 12 months or if you have not received a performance appraisal, please explain why in your application.

Education Documentation: 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. See "Education" for more details.

Certificate of Good Standing: A certified original copy of your certificate of good standing from your State Bar will be required if you are selected.

VETERANS' PREFERENCE DOCUMENTATION: There is no formal rating system for applying veterans' preference to attorney appointments in the excepted service; however, the Office of Chief Counsel considers veterans' preference eligibility as a positive factor in attorney hiring. If you are claiming veterans' preference, you must submit a copy of your Certificate of Release or Discharge from Active Duty, DD-214 (Member 4 copy), or other official documentation from a branch of the Armed Forces or the Department of Veterans Affairs showing dates of service and type of discharge. Ten-point preference eligibles must also submit an , along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference, view .

If you are relying on your education to meet qualification requirements:

Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from .

Failure to provide all of the required information as stated in this vacancy announcement may result in an ineligible rating or may affect the overall rating.