Tax Law Specialist *TEMP Not to Exceed 1 year, May be Extended up to 5 years May be Made PERM*
WHAT IS THE TRANSFER PRICING PRACTICE NETWORK? The Transfer Pricing Practice Network (TPPN) provides technical assistance with transfer pricing and income shifting issues. The TPPN serves as the engine for transfer pricing strategy, training, and data management. The TPPN assists with case consultations, knowledge sharing, developing and delivering training, collaboration and directing teams to educational materials, and special projects. WHAT DOES A TRANSFER PRICING PRACTICE TAX LAW SPECIALIST DO? The Tax Law Specialist (TLS) in the Transfer Pricing Practice (TPP) in the Large Business and International (LBI) division, is an expert in the analysis and resolution of compliance issues relating to 482 of the Internal Revenue Code and related regulations. The TLS serves as a technical expert in the examination of transfer pricing issues. Responsibilities may include risking and auditing related party transactions, preparing proposed adjustments, presenting such positions to taxpayers, identifying emerging transfer pricing tax compliance issues, leading issue work groups, developing and delivering training, and other special projects. As a Transfer Pricing Practice Tax Law Specialist you will:
Participate in the examination of transfer pricing issues including planning, coordinating and executing transfer pricing examinations. May also serve as a consultant for other IRS personnel working transfer-pricing issues and transactions. Collaborate and coordinate with other IRS functions to leverage and expand issue expertise, to ensure consistency in the administration of tax laws. Participate in workgroups focused on international issues including, IRS Practice Networks (PNs). Participate in projects involving the development of international transfer pricing auditing techniques, work practices, and training programs. Perform research and analysis of tax issues involving transfer pricing, and related valuation and economic assessments for specific taxpayers, taxpayer groups or Industries. Provide feedback, technical expertise, and recommendations to IRS management and IRS Counsel on transfer-pricing issues. Identify and discuss issues that require technical advice, field service advice, or industry-wide coordination related to transfer pricing rules and regulations. Interact regularly with personnel in the Advance Pricing and Mutual Agreement program. Ability to prepare, read and report on Cost Sharing Agreements. Experience with reading, interpreting and understanding IRC 367(d) WHERE CAN I FIND OUT MORE ABOUT OTHER IRS CAREERS? If you want to find out more about IRS careers, visit us on the web at www.jobs.irs.gov You must meet the following requirements by the closing date of this announcement:
GS-14 LEVEL:
You must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-13 grade 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 OECD Guidelines related to transfer pricing between US and foreign related parties including transfers of tangible and intangible property, high value services, 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 cross border 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. 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; and serving, where necessary, as a qualified witness for the government in litigation cases.- The experience may have been gained in the public sector, private sector or Volunteer Service. 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 have been at the GS-13 level for 52 weeks (time-in-grade requirement).
Estimated Salary: $20 to $28 per hour based on qualifications.
Participate in the examination of transfer pricing issues including planning, coordinating and executing transfer pricing examinations. May also serve as a consultant for other IRS personnel working transfer-pricing issues and transactions. Collaborate and coordinate with other IRS functions to leverage and expand issue expertise, to ensure consistency in the administration of tax laws. Participate in workgroups focused on international issues including, IRS Practice Networks (PNs). Participate in projects involving the development of international transfer pricing auditing techniques, work practices, and training programs. Perform research and analysis of tax issues involving transfer pricing, and related valuation and economic assessments for specific taxpayers, taxpayer groups or Industries. Provide feedback, technical expertise, and recommendations to IRS management and IRS Counsel on transfer-pricing issues. Identify and discuss issues that require technical advice, field service advice, or industry-wide coordination related to transfer pricing rules and regulations. Interact regularly with personnel in the Advance Pricing and Mutual Agreement program. Ability to prepare, read and report on Cost Sharing Agreements. Experience with reading, interpreting and understanding IRC 367(d) WHERE CAN I FIND OUT MORE ABOUT OTHER IRS CAREERS? If you want to find out more about IRS careers, visit us on the web at www.jobs.irs.gov You must meet the following requirements by the closing date of this announcement:
GS-14 LEVEL:
You must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-13 grade 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 OECD Guidelines related to transfer pricing between US and foreign related parties including transfers of tangible and intangible property, high value services, 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 cross border 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. 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; and serving, where necessary, as a qualified witness for the government in litigation cases.- The experience may have been gained in the public sector, private sector or Volunteer Service. 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 have been at the GS-13 level for 52 weeks (time-in-grade requirement).
- Department:
0987 Tax Law Specialist - Salary Range:
$111,015 to $160,041 per year
Estimated Salary: $20 to $28 per hour based on qualifications.
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