Associate Chief Counsel (PTE) Job in Washington, DC

Vacancy No. CCAS-25-12792765-SES Department Internal Revenue Service
Salary $150,160.00 to $225,700.00 Grade 00 to 00
Perm/Temp Permanent FT/PT Full-time
Open Date 8/29/2025 Close Date 9/26/2025
Job Link Apply Online Who may apply Public
Locations:
Washington, DC


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.

To learn more, click the links below:
IRS Office of Chief Counsel Careers Site
Meet Our People
Learn about our Legal Divisions

Duties

As a key member of the executive staff of the Chief Counsel, the Associate Chief Counsel, Passthroughs, Trusts and Estates (PT&E) is responsible for coordinating and directing all activities of the Associate Office for PT&E within the Office of Chief Counsel, Internal Revenue Service (IRS). The Associate Office of PT&E (Office) provides legal advisory services that support the uniform interpretation, application, enforcement, and litigation of tax laws involving a wide range of business and investment entities. The Office manages the classification of domestic and foreign entities and issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift, and generation skipping taxes (referred to collectively as "transfer taxes") and with Treasury officials and IRS Division Commissioners and other Associate and Division Counsel on program matters, such as identifying and prioritizing emerging issues and publishing guidance.

As the Associate Chief Counsel (PT&E), you will:

  • Serve as the principal legal advisor to the IRS and the Office of Chief Counsel on matters relating to passthrough entities and transfer taxes, publishes public and other technical guidance on such issues, and shares responsibility with the Division Counsel for the direction and oversight of the Counsel-wide litigation program involving passthrough entities and transfer taxes. Represent the IRS and Treasury on sensitive and controversial issues related to these areas.
  • Formulate and direct programs and policies with respect to litigation involving passthrough entities and transfer taxes in the U.S. Tax Court. Assures IRS-wide consistency of approach in tax litigation involving passthrough entities and transfer taxes; consult with the Division Counsel as to the defense or settlement of cases pending in U.S. Tax Court (including the preparation and approval of Chief Counsel actions on decisions) and, review and coordinate pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S. Tax Court litigation involving passthrough entities and transfer taxes.
  • Provide executive direction to staff engaged in drafting revenue rulings, revenue procedures, announcements, and news releases to be published for the guidance of taxpayers and IRS personnel; issuing technical advice memoranda responding to questions raised by IRS examiners; issue private letter rulings and general technical information letters in response to requests from taxpayers; and prepare Chief Counsel Advice and other legal opinions for other Chief Counsel offices and IRS functions with respect to legal questions raised in litigation and IRS programs.
  • Work with Treasury officials to coordinate recommendations for legislation that particularly affects matters involving passthrough entities and transfer taxes; direct IRS participation in this aspect of the legislative process, including the furnishing of advice and guidance with respect to the development of new or revised legislative proposals; oversee IRS participation with legislative staffs in the drafting of such legislation and committee reports.
  • Coordinate the processing and review of nondocketed cases submitted for consideration by various local, area, division, or national levels. Renders legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning issues involving passthrough entities and transfer taxes under examination in the audit of returns, or in the consideration of claims for refund. Develop and monitor performance measures and program goals for the provision of legal services and published guidance, and the implementation, compliance, and outreach initiatives on issues involving passthrough entities and transfer taxes.
  • Plan, direct, and coordinate nationwide programs relating to passthrough entities and transfer taxes, including with respect to all personnel, fiscal and budgetary requests and recommendations. Balance the diverse needs of program segments and determine the allocation and deployment of human and fiscal resources that best positions the organization to meet the needs of clients as a whole.
  • Direct and oversee the overall management of the division's legal staff. Ensure all management functions are handled equitably and in a manner that is responsive to the needs of all programs that the division supports. Ensure sound position management policy. Take positive steps in support of all merit system principles.
  • Perform other duties as assigned.

Requirements

Conditions of Employment

  • Refer to "Additional Information"
  • Click "Print Preview" to review the entire announcement before applying.
  • Must be a U.S. Citizen or National

Qualifications

To qualify for this position of Associate Chief Counsel (PT&E) you must meet the following requirements:

  • 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;
  • Desired Education/Experience: An LL.M. in Taxation is desired but not required. Seven (7) years of professional legal tax experience is desired.

As a basic requirement for entry into the SES, applicants must provide evidence of progressively responsible executive leadership and supervisory experience that is indicative of senior executive level managerial capability. The ideal candidate will have experience supervising many employees through subordinate supervisors and have experience hiring, developing, and evaluating employees. Typically, experience of this nature is at the GS-15 or equivalent level in the federal service or its equivalent in the private sector.

To meet the minimum qualifications, you must submit a two-page resume that shows you possess the five Executive Core Qualifications (ECQs) and Technical Qualifications (TQs). To be considered, the resume must not exceed two pages. If selected for this position you will be required to address each ECQ during a structured interview with the Office of Personnel Management (OPM) Qualifications Review Board (QRB). Written narratives for the ECQs are not required.

Current and former career SES employees, and OPM Candidate Development Program (CDP) graduates are exempt to address the ECQs.

By statute, OPM prescribes Executive Core Qualifications (ECQs) for the appointment of career SES members. The ECQs were designed to evaluate executive experience and not technical expertise. The following ECQs provide the focus for certification of executive core qualifications for initial appointment to the Senior Executive Service. Your two-page resume should show that you possess the Executive Core Qualifications listed below:

  1. Commitment to the Rule of Law and the Principles of the American Founding: This core qualification requires a demonstrated knowledge of the American system of government, commitment to uphold the Constitution and the rule of law, and commitment to serve the American people.
  2. Driving Efficiency: This core qualification involves the demonstrated ability to strategically and efficiently manage resources, budget effectively, cut wasteful spending, and pursue efficiency through process and technological upgrades.
  3. Merit and Competence: This core qualification involves the demonstrated knowledge, ability and technical competence to effectively and reliably produce work that is of exceptional quality.
  4. Leading People: This core qualification involves the demonstrated ability to lead and inspire a group toward meeting the organization's vision, mission, and goals, and to drive a high-performance, high- accountability culture. This includes, when necessary, the ability to lead people through change and to hold individuals accountable.
  5. Achieving Results: This core qualification involves the demonstrated ability to achieve both individual and organizational results, and to align results to stated goals from superiors.
Additional information on ECQs is in OPM's Guide to SES Qualifications. Applicants are strongly encouraged to follow the Challenge, Context, Action and Results model outlined in the guide, to prepare for the structured interview. Written narratives for the ECQs are not required; however, applicants must be prepared to address each ECQs in a structured interview with the QRB.

In addition to the ECQs, candidates must address Technical Qualifications (TQs). TQs are designed to assess an applicant's experience relevant to the specific position requirements. All applicants must clearly demonstrate in their two-page resume, experience and accomplishments related to the TQs below:

TECHNICAL QUALIFICATIONS (TQs):

  1. Demonstrated ability to develop nationwide strategies and provide dedicated support and legal advice to high profile significant IRS top ranking officials and provide effective quality legal services to both internal and external customers.
  2. Demonstrated comprehensive, professional knowledge of and experience in applying tax laws affecting passthrough entities and activities, classification of domestic and foreign entities, and issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift and generation skipping taxes.

Desirable:

  1. A thorough understanding of the operations and organization of the Internal Revenue Service and Office of Chief Counsel.

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.

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 Department of Education Accreditation page.

FOREIGN EDUCATION: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. For further information, visit: Recognition of Foreign Qualifications | International Affairs Office (ed.gov)

Additional information

  • Relocation expenses may be authorized for current Federal Employees.
  • This is a non-bargaining unit position.
  • We offer opportunities for telework.
  • We offer opportunities for flexible work schedules.
Conditions of Employment Continued:
  • Subject to a 1-year trial period (unless already completed).
  • You will serve a one-year Senior Executive Service (SES) probationary period unless you previously completed the probationary period in the SES.
  • Complete a Declaration for Federal Employment to determine your suitability for Federal employment, at the time requested by the agency
  • If you are a male applicant born after December 31, 1959, certify that you have registered with the Selective Service System or are exempt from having to do so.
  • Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.
  • Go through a Personal Identity Verification (PIV) process that requires two forms of identification from the Form I-9. Federal law requires verification of the identity and employment eligibility of all new hires in the U.S.
  • Public Trust (85PS) Background Investigation required
  • Obtain and use a Government-issued charge card for business-related travel.
  • File a Confidential Financial Disclosure Report OGE-278e within 30 days of appointment and annually from then on.
  • Undergo an income tax verification.
  • The employment of any candidate, including a current employee or a new hire, selected for this position may be conditional upon classification and/or audit of federal tax returns. This audit may include up to 2 years of returns.
  • This position requires that the successful candidate undergo personnel vetting, which includes a background investigation and enrollment upon onboarding into "Continuous Vetting." Enrollment in Continuous Vetting will result in automated record checks being conducted throughout one's employment with Treasury. The successful candidate will also be enrolled into FBI's Rap Back service, which will allow Treasury to receive notification from the FBI of criminal matters (e.g., arrests, charges, convictions) involving enrolled individuals in near real-time.

    There are three key documents that contain important information about your rights and obligations. Please read and retain these documents:
  • Noncriminal Justice Applicant's Privacy Rights, for those who undergo an FBI fingerprint-based criminal history record check for personnel vetting, which includes Rap Back,
  • FD-258 Privacy Act Statement - FBI (this is the same statement used when your fingerprints are submitted as part of your background investigation), and
  • SEAD-3-Reporting-U.pdf (dni.gov), (applicable to those who hold a sensitive position or have eligibility for access to classified information)"

Candidates should be committed to improving the efficiency of the Federal government, passionate about the ideals of our American republic, and committed to upholding the rule of law and the United States Constitution.

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. Opens in a new windowLearn more about federal benefits.

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.

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 for the initial selection may be held at the option of the Executive Resources Board (ERB). All application materials and interviews, if conducted, will be used in the final evaluation and selection process.

Candidates found minimally qualified will be further evaluated by the ERB based on the extent and quality of their experience as it relates to the ECQs and technical qualifications (TQs) needed for this position. Appropriate consideration will be given for job-related training, education, awards, publications, and supervisory appraisals of job performance.

(Note: Current and former SES members, and other candidates who have already been OPM/QRB-certified, are not required to address the executive core qualifications. They must, however, provide documentation of certification in the form of an SF-50 showing career SES status, or an OPM issued SES qualification certificate.)

Referral: 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.

Required Documents

A complete application includes 1. A resume, 2. Vacancy questionnaire 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).

1. RESUME: All applicants are required to submit a two-page resume (NOT TO EXCEED 2 PAGES). To receive full credit for relevant experience, please list the month/year and number of hours worked for experience listed on your resume. Please view resume tips. Resume should clearly state your experience related to this position as described in the Duties section and Qualifications section.

2. VACANCY QUESTIONNAIRE RESPONSES: Responses are automatically submitted through USA Jobs when you apply to this vacancy.

3. ADDITIONAL REQUIRED DOCUMENTS: In addition, applicants are required to submit the following supporting documentation:

  • Memorandum of Interest
  • Performance Evaluation (not more than 2 years old)
SENIOR EXECUTIVE SERVICE (SES) NONCOMPETITIVE APPLICANTS: If you are currently serving under a career SES appointment, are eligible for reinstatement into the SES, or have successfully completed a SES Candidate Development Program approved by OPM, proof of SES noncompetitive eligibility must be submitted:
  • SF-50 showing your status as a current Career SES appointee, former Career SES appointee with career SES reinstatement eligibility, or current or reinstatement eligible Career SES-equivalent executive who is/was employed in a Federal government agency that has an interchange agreement with the Office of Personnel Management (OPM) allowing for movement between the agency's SES-equivalent personnel system and the SES; OR
  • A certificate of completion from an OPM-approved SES Candidate Development Program (CDP). This applies only if your ECQs have been approved by an OPM Qualifications Review Board through the SES CDP.
  • Note: Former Career Reserve Senior Executive Service employees and graduates of a SES Candidate Development Program who have been certified by OPM's QRB are not required to address the ECQs
EDUCATION DOCUMENTATION: For positions with an education requirement, submit a copy of your transcripts or equivalent. An official transcript will be required if you are selected and not already on file. See "Education" for more details.

PROFESSIONAL CERTIFICATION: If selected, you will be required to submit an original Certificate of Good Standing from your State Bar if not already received by the agency.

How to Apply

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 the closing date of this announcement. To preview the Application Questionnaire, please click the following link: https://apply.usastaffing.gov/ViewQuestionnaire/12792765

  • To begin, click Apply to access the online application. You will need to be logged into your USAJOBS account to apply. If you do not have a USAJOBS account, you will need to create one before beginning the application.
  • Follow the prompts to select your resume and/or other supporting documents to be included with your application package. You will have the opportunity to upload additional documents to include in your application before it is submitted. Your uploaded documents may take several hours to clear the virus scan process.
  • After acknowledging you have reviewed your application package, complete the Include Personal Information section as you deem appropriate and click to continue with the application process.
  • You will be taken to the online application which you must complete in order to apply for the position. Complete the online application, verify the required documentation is included with your application package, and submit the application. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete.
  • It is your responsibility to verify that your application package (resume, supporting documents, and responses to the questionnaire) is complete, accurate, and submitted by the closing date. Uploaded documents may take up to one hour to clear the virus scan.
  • Additional information on how to complete the online application process and submit your online application may be found on the USA Staffing Applicant Resource Center.

Agency contact information

IRS CC Office of Executive Resources
Address
Office of Chief Counsel, IRS
Staffing and Classification Branch
1111 Constitution Ave, NW
Washington, DC 20224
US

Next steps

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Note: We cannot accept applications on behalf of Federal Agencies. Application instructions are listed within the Job Description.