Tax Law Specialist at US Internal Revenue Service

US Internal Revenue Service

Full-Time

Mid Level

Denver, CO, USA

$110.000 - $160.000

19 May → 18 Jun

Job Description

The Transfer Pricing Practice (TPP) is part of Treaty and Transfer Pricing Operations (TTPO) in the Large Business & International (LB&I) division of the IRS. Transfer pricing essentially involves the pricing of goods, services, and intellectual property transferred between related entities of multinational enterprises (typically corporations with a common parent company). When these transactions involve related entities located in foreign countries, tax issues arise over how much income should be reported in each country. The United States and foreign tax administrations have complex tax rules about how intercompany pricing is to be determined and income reported. It is an area of significant tax controversy, not only in the United States, but also in numerous countries around the world. The IRS Transfer Pricing Practice conducts many types of compliance activities related to transfer pricing. Those activities include examination cases, Compliance Assurance Process (CAP) cases, Campaigns (which may or may not include examinations), assisting with Advance Pricing Agreement matters, and other efforts. The Practice Network supports those working on transfer pricing issues in TTPO by performing risk assessments and identifying emerging issues or issues of strategic importance. In addition, the Practice Network develops training in transfer pricing issues, provides advice to campaigns and assists agents in transfer pricing tax examinations.

Occasional travel - You may be expected to travel for this position.

Job Responsibilities

  • Assists Examination Teams in planning, directing, and coordinating the examination of international transfer-pricing issues. The incumbent 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. The incumbent may also be assigned to work closely with IRS 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 IRS, and to ensure consistent application and interpretation of international tax law. The incumbent regularly participates in groups focused on international issues including, but not limited to, 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. The incumbent develops and conducts training sessions and holds periodic meetings with IRS 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 IRS management and IRS Counsel on transfer-pricing issues. The International Transfer Pricing Specialist identifies and discusses any issues that require technical advice, field service advice, or industry-wide coordination procedures to be followed.

Requirements / Qualifications

  • If you are in a telework eligible position, you may be directed to temporarily telework on a full-time basis due to COVID 19. Employees must be within a 150-mile radius of their official assigned post-of-duty (POD) while in a telework status. Once normal operations resume, employees may be directed back to the office to perform the duties of their position. Telework eligibility does not guarantee telework; employees must meet and sustain IRS telework eligibility requirements and supervisor's approval to participate in the IRS Telework Program. 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.

  • Must be a U.S. Citizen or National.

  • A 1-year probationary period is required.

  • Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer.

  • Must successfully complete a background investigation, including a FBI criminal history record check (fingerprint check).

  • 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.

  • 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. These documents must be unexpired original or certified copies.

  • Provide proof of U.S. Citizenship. (Birth certificate showing birth in the U.S; Unexpired U.S. Passport; Certificate of Citizenship or Naturalization; or Report of Birth Abroad of a U.S. Citizen (Form FS-240))

  • 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.

  • Obtain and use a Government-issued charge card for business-related travel.

How To Apply

Apply through LegalJobs. 

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