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Summary Click on "Learn more about this agency" button below to view Eligibilities being considered and other IMPORTANT information. WHERE CAN I FIND OUT MORE ABOUT OTHER IRS CAREERS? Visit us on the web at www.jobs.irs.gov Responsibilities WHAT IS THE INDEPENDENT OFFICE OF APPEALS DIVISION? A description of the business units can be found at: https://www.jobs.irs.gov/about/who/business-divisions Vacancies will be filled in the following specialty areas: Independent Office of Appeals: Specialized Exam Programs & Referrals/Area 11. The following are the duties of this position at the full working level. If this vacancy includes more than one grade and you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and receive training to help you grow in this position. Performs analysis and conducts Appeals conferences for the resolution and settlement of international tax issues under the jurisdiction of the Independent office of Appeals. Cases assigned at this level are characterized by a lack of clearly applicable precedents/procedures regarding issues that are either novel, complex, or involve different possible interpretations of fact and law. Determines tax treatment of foreign tax credits, taxable income and income exclusion for U.S. Taxpayers living abroad or doing business in foreign jurisdictions. Determines the same for foreign taxpayers doing business and earning income in the United States. Determines assessment and abatement of international penalties and Title 31 penalties. Receives and works cases and issues which have been referred by Appeals management when the tax issues warrant the services of an International Specialist. Serves as an expert in determining a final settlement and resolving appealed cases that involve international tax issues with difficult legal or factual questions where precedents are unavailable or not clearly applicable and there are large sums of money involved. Reviews international case files, supporting documents, and other information germane to the determination of tax liability. Analyzes case files to determine issues of fact and law. Reconciles apparent factual discrepancies by further investigation, reconstruction, and/or the determination of the interpretation most consistent with all available evidence. Requirements Conditions of Employment STANDARD POSITION DESCRIPTIONS (SPD): PD97792 Visit the IRS SPD Library to access the position descriptions. Telework Eligible Positions: Telework eligible positions do not guarantee telework. Employees must meet and sustain IRS telework eligibility requirements (e.g., reporting at least twice a pay period to your assigned Post of Duty (POD)) and supervisor's approval to participate in the IRS Telework Program. Employees must also be within a 200-mile radius of their official assigned post-of-duty (POD) while in a telework status. As a reminder - If you are selected for a position, you are responsible for reporting to your designated POD (location) on the negotiated start date or as directed by management. File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on. Obtain and use a Government-issued charge card for business-related travel. We may select from this announcement or any other source to fill one or more vacancies. Additional jobs may be filled. The salary range indicated in this announcement reflects the minimum locality pay up to maximum locality pay for all duty locations listed. The range will be adjusted for selected duty location. General Schedule locality pay tables may be found under Salaries & Wages. This is a bargaining unit position. Tour of Duty: Monday - Friday, 8:00AM - 4:30PM. Alternative work schedule, staggered work hours or telework may be available. Relocation expenses - none. See Additional Information below for cut-off dates. Please consider each location carefully when applying. If you are selected for a position at one of your location selections, that location will become your official post of duty. Qualifications You must meet the following requirements by the closing date of this announcement: SPECIALIZED EXPERIENCE: GS-13 LEVEL: You must have 1 year of specialized experience at a level of difficulty and responsibility equivalent to the GS-12 grade level in the Federal service. Specialized experience for this position includes all of the following: Experience applying professional accounting principles, theory, and practices to analyze and interpret accounting books, records, or systems specifically to determine the effect on tax liabilities or financial statements; Experience recognizing and assessing the complexity of accounting or legal issues; Experience applying professional legal principles, theory, and practices to analyze and interpret legal issues specifically to determine effect on tax liabilities or financial statements; Experience interpreting the law in situations where there are uncertainties or conflicts in statutes, regulations, case law, precedence or other guidance to determine and apply the appropriate intent of the law in tax situations; Experience conducting legal research and applying the law to tax situations; Familiar with litigation procedures and making judgments involving matters of law particularly as they relate to resolving tax disputes. In addition to the above, you must have experience reviewing and analyzing tax treaties between the United States and foreign governments to apply and resolve cases relevant to tax laws in foreign countries, economic theory, exchange rates, contract laws, immigration laws, and bank secrecy laws. Experience in applying tax and accounting principles in the resolution of tax disputes. Such topics include one or more of the following: accounting methods and principles used in foreign countries, tax treatment of foreign tax credits, determining taxable income and income exclusions for U. S. Taxpayers living abroad or conducting business in foreign jurisdictions, taxable income determinations for foreign taxpayers conducting business and earning income in the United States, determining assessment and abatement of international penalties and Title 31 penalties. AND MEET TIME IN GRADE (TIG) REQUIREMENT: You must meet applicable TIG requirements to be considered eligible. To meet TIG for positions above the GS-05 grade level, you must have served at least one year (52 weeks) at the next lower grade (or equivalent) in the normal line of progression for the position you are applying to. Advancement to positions up to GS-05 is permitted if the position to be filled is no more than two grades above the lowest grade held within the preceding 52 weeks. AND TIME AFTER COMPETITIVE APPOINTMENT: By the closing date (or if this is an open continuous announcement, by the cut-off date) specified in this job announcement, current civilian employees must have completed at least 90 days of federal civilian service since their latest non-temporary appointment from a competitive referral certificate, known as time after competitive appointment. For this requirement, a competitive appointment is one where you applied to and were appointed from an announcement open to "All US Citizens". Federal experience is not required. 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-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. For more information on qualifications please refer to OPM's Qualifications Standards. Education A copy of your transcripts or equivalent documentation is required for positions with an education requirement, or if you are qualifying based on education or a combination of education and experience. An official transcript will be required if you are selected. If the position has specific education requirements and you currently hold, or have previously held, a position in the same job series with the IRS, there is no need to submit a transcript or equivalent at this time. Applicants are encouraged, but are not required, to submit an SF-50 documenting experience in a specific series. 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: Education completed in foreign colleges or universities may be used to meet the requirements. You must show proof the education credentials have been deemed to be at least equivalent to that gained in conventional U.S. education program. It is your responsibility to provide such evidence when applying. Click here for Foreign Education Credentialing instructions. Additional Information This is an open continuous announcement which will be used to fill vacancies in the locations listed as they become available for the next 12 months contingent upon funding and space requirements. Applicants must apply and/or update their applications by 11:59 pm ET at the close of the following cutoff dates to be considered: Cutoff date(s): 1/3/2024, 4/3/2024, 7/3/2024, and 10/3/2024. This announcement may be amended to include additional cut-off dates within the 12 month period if needed, not later than 10 days prior to the additional cut-off date(s). Eligible applicants who apply by the initial cut-off date, will be referred in score order. If additional vacancies exist, remaining applicants will be considered in score order as needed. Selections from this announcement may be made no later than 1/3/2025. If the position(s) are no longer needed prior to the closing date, this announcement may be closed early.