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Tax - General Attorney in Glendale, CA

Internal Revenue Service (IRS) Jun 01,2023 Jan 20,2023 Location USA Glendale CA
This job is expired...

Government

Attorney

Tax - General

Min 1 yrs required

Profile

Tax Law Specialist, GS 14 Duties: The candidate assists Examination Teams in planning, directing, and coordinating the examination of international transfer-pricing issues. 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. May also be assigned to work closely with 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 Agency, and to ensure consistent application and interpretation of international tax law. Regularly participates in groups focused on international issues including, 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. Develops and conducts training sessions and holds periodic meetings with the Agency 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 the management and Agency Counsel on transfer-pricing issues. Identifies and discusses any issues that require technical advice, field service advice, or industry-wide coordination procedures to be followed.

Qualification and Experience

Qualifications: The candidate must have 1 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, transactions, and controversies, including application of the Internal Revenue Code, corresponding Treasury Regulations, tax treaties, Court decisions and the Organization for Economic Cooperation and Development (OECD) Guidelines related to transfer pricing between US and foreign related parties including transfers of tangible and intangible property, high value services, asset valuations, and risk allocation; Applying auditing techniques to multiple, interrelated transfer pricing issues as listed above on large corporate returns. Performing research and analysis of transfer pricing issues; conducting various kinds of audit steps verifying taxpayers' economic structure, business practices and functions; reviewing and analyzing economic, financial, operational and tax data to determine the existence of a potential transfer pricing issue; performing analyses to determine and/or evaluate tax reporting of intercompany transactions; providing technical advice concerning transfer pricing issues on cases; providing advice and recommendations to other examiners within issue networks during workshops and other knowledge sharing forums. Experience preparing and delivering written and oral communications to explain and defend the Government's position related to transfer pricing; holding conferences with taxpayers, their representatives and others to present and discuss transfer pricing positions and analysis; Experience serving, where necessary, as a qualified witness for the government in litigation cases. Experience assisting on competent authority cases or advance pricing agreements; correlative adjustments, set offs, or commensurate with income; and experience with treaty partners such an exchange of Information (EOI), Joint Audit, or International Compliance Assurance Program (ICAP).

Note: This job is open to federal employees who meet the definition of a surplus or displaced employee and current federal employees of this agency.

Application Deadline: October 13, 2023.

Additional info

Announcement Number: 23-11770514M-LBB-0987-14. Apply online. No emails. Visit website for more information.

Company info