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.
This job is open to
Clarification from the agency
U.S. Citizens and U.S. Nationals; no prior Federal experience is required.
Duties
As a key member of the executive staff of the Chief Counsel, the Associate Chief Counsel (Partnerships, S corporations, Trusts, and Estates) is responsible for coordinating and directing all activities of the Associate Office for Partnerships, S corporations, Trusts, and Estates and Gifts, within the Office of Chief Counsel, Internal Revenue Service (IRS).
The Associate Office of Partnerships, S corporations, Trusts, and Estates (Office) is comprised of approximately fifty attorneys, tax law specialists, and support employees in Washington, D.C.; and 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, including partnerships, S corporations, trusts, and estates (passthrough entities and certain transfer taxes - referred to below collectively as "transfer taxes").
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 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.
MAJOR DUTIES AND RESPONSIBILITIES:
Major duties include but are not limited to:
- Serves 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. Represents the IRS and Treasury on sensitive and controversial issues related to these areas.
- Formulates and directs 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; consults 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, reviews and coordinates 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.
- Provides 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; issuing private letter rulings and general technical information letters in response to requests from taxpayers; and preparing 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.
- Works with Treasury officials to coordinate recommendations for legislation that particularly affects matters involving passthrough entities and transfer taxes; directs 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; oversees IRS participation with legislative staffs in the drafting of such legislation and committee reports.
- Coordinates 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. Develops and monitors 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.
- Plans, directs, and coordinates nationwide programs relating to passthrough entities and transfer taxes, including with respect to all personnel, fiscal and budgetary requests and recommendations. Balances the diverse needs of program segments, and determines the allocation and deployment of human and fiscal resources that best positions the organization to meet the needs of clients as a whole.
- Directs and oversees the overall management of the division's legal staff. Ensures all management functions are handled equitably and in a manner that is responsive to the needs of all programs that the division supports. Ensures sound position management policy. Takes positive steps in support of all merit system principles.
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
The incumbent is expected to have substantial experience in managerial roles requiring application of broad, comprehensive, professional knowledge and experience in applying federal tax laws. Comprehensive knowledge of the tax laws that affect passthrough entities and activities, including partnerships, S corporations, trusts, estates, classification of domestic and foreign entities, issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift, and generation skipping taxes, is required.
Work involves highly sensitive and intricate matters under the jurisdiction of the Associate Chief Counsel. The incumbent must have demonstrated ability to think critically, and approach issues creatively to effectively resolve problems of substantial impact, sensitivity, and complexity; and make decisions that produce high-quality results by applying technical knowledge, performing detailed legal analysis and research on problems of unusual delicacy, as well as calculating risks. Professional experience should encompass managing a large-scale legal projects, including the ability to review and assess the organizational effectiveness of program services and policies, and to design and implement procedures to improve and optimize organizational performance; as well as translate long term goals and objectives into short term tactical plans and operational activities; and supervise others to promote maximum use and development of staff, and to support equal employment opportunity initiatives and goals.
The Associate Chief Counsel (Partnerships, S corporations, Trusts, and Estates) must maintain effective working relationships, communicate effectively, and deal tactfully and diplomatically with key officials, including the IRS Commissioner, senior officials at Treasury, as well as other agencies, key external and internal stakeholders, and represent the Office of Chief Counsel in executive and professional meetings; and facilitate communications between individuals with differing points of view. Contacts may also include key members of professional associations and other tax practitioners/experts.
Graduation from an ABA accredited law school and current possession of a bar membership which permits the practice of law in the United States is required, including a thorough knowledge of the American Bar Association's Model Code of Professional Responsibility.
A) Executive Core Qualifications (ECQs):
Prospective candidates must have and clearly describe leadership experiences that demonstrate the executive level managerial capabilities comprising the Executive Core Qualifications (ECQ's) of the Senior Executive Service; and certification by the Office of Personnel Management's Qualification's Review Board (QRB), required for initial career appointment to the Senior Executive Service. Typically, experience of this nature is gained at or above the GS-15 grade level or its equivalent in Federal service or with state or local government, the private sector, or nongovernmental organizations.
- Leading Change - Ability to bring about strategic change, both within and outside the organization, to meet organizational goals. Ability to establish an organizational vision and to implement it in a continuously changing environment.
- Leading People - Ability to lead people toward meeting the organization's vision, mission, and goals. Ability to provide an inclusive workplace that fosters the development of others, facilitates cooperation and teamwork, and supports constructive resolution of conflicts.
- Results Driven - Ability to meet organizational goals and customer expectations. Ability to make decisions that produce high-quality results by applying technical knowledge, analyzing problems, and calculating risks.
- Business Acumen - Ability to manage human, financial, and information resources strategically.
- Building Coalitions - Ability to build coalitions internally and with other Federal agencies, State and local governments, nonprofit and private sector organizations, foreign governments, or international organizations to achieve common goals.
Additional information on ECQs is available at: http://www.opm.gov/policy-data-oversight/senior-executive-service/executive-core-qualifications/ . Applicants are strongly encouraged to follow the Challenge, Context, Action and Results model outlined in the guide. It is recommended that you draft your ECQs in a Word document and then upload into the system.
Individuals selected for an initial SES appointment must serve a one-year probationary period.
B) Mandatory Technical Competencies (MTQs):
In addition to the general managerial competencies set out in the Executive Core Qualifications and mandatory for all Senior Executive Service positions, candidates must show evidence of the following more specific competencies in order to meet basic qualifications for this position:
- Position requires comprehensive, professional knowledge of and experience in applying tax laws affecting passthrough entities and activities (i.e., partnerships, S corporations, trusts), 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.
- Must have demonstrated the ability to manage a legal services program, including the ability to review and assess the organizational effectiveness of program services and policies, and to design and implement procedures to improve/optimize organizational performance.
- Must have demonstrated the ability to make effective, decisive, timely and well-considered decisions, and to resolve issues/problems of substantial impact, sensitivity, and complexity.
- Must have demonstrated the ability to supervise others to promote maximum utilization and development of staff and to support equal employment opportunity initiative and goals.
C) Desirable:
- A thorough understanding of the operations and organization of the Internal Revenue Service and Office of Chief Counsel, and a solid understanding of the Department of the Treasury and its Office of General Counsel.
(Note: Failure to address these factors will result in your application being disqualified.) Narrative responses to the Technical Qualifications and Desirable Qualifications should not be more than two pages for each. Please provide the Executive Core Qualifications, Technical Qualifications and Desirable Qualifications each on separate sheets of paper.
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: http://www.ed.gov/about/offices/list/ous/international/usnei/us/edlite-visitus-forrecog.html.
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 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.
Candidates found minimally qualified will be further evaluated by an Executive Resources Board based on the extent and quality of their experience as it relates to the Mandatory Technical Competencies and the Executive Core Qualifications needed for this position. Appropriate consideration will be given for job-related training, education, awards, publications, and supervisory appraisals of job performance. Interviews of applicants may be held at the option of the Board. Selected applicant will be subject to certification of their executive qualifications by the U.S. Office of Personnel Management (unless previously certified). (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. Executive Core Qualifications (ECQs), 3. Mandatory Technical Qualifications (MTQs), 4. Vacancy Question Responses, and 5. 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 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 resume tips. Resume should clearly state your experience related to this position as described in the Duties section and Qualifications section.
2. EXECUTIVE CORE QUALIFICATIONS (ECQs)- A separate narrative statement of 10-pages or less that addresses each of the five ECQs separately as described above.
3. MANDATORY TECHINCAL QUALIFICATION (MTQs) - A separate narrative statement of 10-pages or less that addresses each of the MTQs separately as described above.
4. VACANCY QUESTION RESPONSES: Responses are automatically submitted through USA Jobs when you apply to this vacancy
5. ADDITIONAL REQUIRED DOCUMENTS: In addition, applicants are required to submit the following supporting documentation:
- Memorandum of Interest summarizing your interest in the position.
- CHIEF COUNSEL EMPLOYEES ONLY: A Supervisory Report (ERB Form 1-88, 4/11) regarding your suitability for the position as completed by your current or most recent supervisor. You are responsible for notifying your supervisor that this report must be received no later than five workdays after the closing date of this announcement.
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 July 12, 2024 and/or cut-off dates in this announcement. We are available to assist you during business hours (normally 7:00 a.m. to 3:30 p.m. ET, Monday - Friday). To preview the Application Questionnaire, please click the following link: https://apply.usastaffing.gov/ViewQuestionnaire/12443949
- 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.
Next steps
To verify the status of your application, log into your USAJOBS account (https://my.usajobs.gov/Account/Login), all of your applications will appear on the Welcome screen. The Application Status will appear along with the date your application was last updated. For information on what each Application Status means, visit: https://www.usajobs.gov/Help/how-to/application/status/.
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