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Tax Law Specialist (International Transfer Pricing Specialist)

Company: The Department of the Treasury
Location: Laguna Niguel
Posted on: March 18, 2020

Job Description:



WHAT IS THE LARGE BUSINESS & INTERNATIONAL (LB&I) DIVISION? The Large Business & International (LB&I) business unit provides service and enforcement activities to support tax compliance of businesses and related entities with assets of $10 million or more, as well as small U.S. businesses engaged in international, U.S. citizens abroad and foreign persons and businesses with a U.S. tax requirement.

See Other Information for Locations


WHAT DOES A TRANSFER PRICING PRACTICE TAX LAW SPECIALIST DO? The Tax Law Specialists (TLS) 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 include auditing related party transactions, preparing proposed adjustments and presenting such positions to taxpayers.

As a Transfer Pricing Practice Tax Law Specialist you will:

  • Participate in the examination of transfer pricing issues to include 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.

    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

    Travel Required

    25% or less - 1 to 5 nights per month

    Supervisory status


    Promotion Potential



    Conditions of Employment
    • Refer to Other Information.
    • Click "Print Preview" to review the entire announcement before applying.
    • Must be a U.S. Citizen or National
    • IRS Employees with Career or Career Conditional Appointments



      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 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 serveing, 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 . 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.

      In addition to the above requirements, you must meet the following, if applicable:
      You must have been at the GS-13 level for 52 weeks (time-in-grade requirement).


      Additional information

      16 positions are located in the following locations:24000 Avila Road, Laguna Niguel, CA (CA0521), 450 Golden Gate Ave, San Francisco, CA (CA0154), 55 South Market Street, San Jose, CA (CA6116), 1999 Broadway, Denver, CO (CO1811), 999 N Capitol St NE, Washington, DC (DC0221), 51 SW First Avenue, Miami, FL (FL0061), 761 Main Avenue, Suite 1000, Norwalk, CT (CT3438), 2203 N Lois Avenue, Tampa, FL (FL2971), 575 N Pennsylvania, Indianapolis, IN (IN0133), 15 New Sudbury Street, Boston, MA (MA0131), 118 Turnpike Road, Southborough, MA (MA5863), 200 Sheffield Street, Mountainside, NJ (NJ4360), 38275 West Twelve Mile Road, Suite 200, Farmington Hills, MI (MI2097), 3251 N Evergreen Dr NE, Grand Rapids, MI (MI2210), 1550 American Blvd East, Bloomington, MN (MN1675), 10715 David Taylor Drive, Charlotte, NC (NC2598), 130 South Elmwood Avenue, Suite 100, Buffalo, NY (NY7340), 200 N High St, Columbus, OH (OH0208), 601 S. Henderson Road, King Of Prussia, PA (PA0507), 1000 Liberty Avenue, Pittsburgh, PA (PA0233), 4050 Alpha Rd, Farmers Branch, TX (TX0302), 1919 Smith, Houston, TX (TX0298), 400 North Eighth Street, Richmond, VA (VA0088), 230 S. Dearborn Street, Chicago, IL (IL0236), 2001 Butterfield Road, Downers Grove, IL (IL2337), 2888 Woodcock Blvd, Atlanta, GA (GA2004)

      A PM/C SharePoint site is available for IRS Employees at:

      • We may select from this announcement or any other source to fill one or more vacancies.
      • This is a bargaining unit position.
      • Alternative work schedule, staggered work hours or telework may be available.
      • Must meet IRS telework eligibility requirements
      • Tour of Duty: Monday - Friday 8:00 a.m. - 4:30 p.m.
      • 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.
      • If you are an IRS/Treasury employee eligible for consideration under the Career Transition Assistance Plan (CTAP), you must submit proof of eligibility by 11:59 PM ET on the closing date of this announcement. If you have any questions concerning your eligibility, please refer back to the CTAP Documentation link in the vacancy under How You Will Be Evaluated.

        How You Will Be Evaluated

        You will be evaluated for this job based on how well you meet the qualifications above.

        Your application includes your resume, responses to the online questions, and required supporting documents. Please be sure that your resume includes detailed information to support your qualifications for this position; failure to provide sufficient evidence in your resume may result in a "not qualified" determination.
        Rating: Your application will be evaluated on the CJEs of the position to be filled per the National Agreement Article 13. Your application will also be rated and ranked among others, based on your responses to the online questions, regarding your experience, education, training, performance appraisals and awards relevant to the duties of this position. IRS employees may obtain most recent awards listing at . Your rating may be lowered, if your responses to the online questions are not supported by the education and/or experience described in your application.

        Referral: If you are among the top qualified candidates, your application may be referred to a selecting official for consideration. You may be required to participate in a selection interview (telephonic and/or in person at the discretion of the Selecting Official in accordance with hiring polices). We will not reimburse costs related to the interview such as travel to and from the interview site.

        If you are a displaced or surplus Treasury employee eligible for the , you must receive a score of 80 or better to be rated as well qualified to receive special selection priority.

        To preview questions please .

        Background checks and security clearance

        Security clearance

        Drug test required


        Required Documents

        A complete application includes 1. A resume, 2. Vacancy question 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 will not be considered for this position (or may not receive the special consideration for which you may be eligible).

        All applicants are required to submit a resume either by creating one in USAJOBS or uploading one of their own choosing. ( 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

        Career Transition Assistance Plan (CTAP) DOCUMENTATIONIf you are a displaced or surplus Treasury employee, click for eligibility and a detailed list of required documents. IRS CTAP eligibles can apply for jobs within and outside the commuting area.

        IRS Reassignment Preference Program (RPP)You must meet the requirements in your RPP notice. Submit a copy of your RPP Notice along with a copy of your most recent annual performance appraisal. Your performance appraisal must have a fully successful or higher overall rating.

        PERFORMANCE APPRAISAL/AWARDSSubmit a copy of your most recent completed performance appraisal.

        IRS employees: if a revalidated appraisal is used for merit promotion, the supervisor must prepare a narrative for each critical job element that does not have a narrative describing the performance in the appraisal period covered by the rating. Note: If you are a manager or management official, your most recent annual performance appraisal must be used for the overall rating identified.

        EDUCATION DOCUMENTATIONIf you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. If the position has specific education requirements and you are currently (or have previously been) in the Federal job series to be filled, there is no need to submit a transcript or equivalent at this time. 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 .

        If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. Refer to the

        If you are relying on your education to meet qualification requirements:

        Education must be accredited by an accrediting institution recognized by the U.S. Department of Education in order for it to be credited towards qualifications. Therefore, provide only the attendance and/or degrees from schools accredited by accrediting institutions recognized by the U.S. Department of Education.

        Failure to provide all of the required information as stated in this vacancy announcement may result in an ineligible rating or may affect the overall rating.Overview

        Open & closing dates
        03/11/2020 to 03/24/2020


        Pay scale & grade
        GS 14

        $107,807 to $170,800 per year

        Appointment type

        Work schedule

        Fair & Transparent

        The Federal hiring process is setup to be fair and transparent. Please read the following guidance.

        Equal Employment Opportunity Policy

        The United States Government does not discriminate in employment on the basis of race, color, religion, sex (including pregnancy and gender identity), national origin, political affiliation, sexual orientation, marital status, disability, genetic information, age, membership in an employee organization, retaliation, parental status, military service, or other non-merit factor.

        • Reasonable Accommodation Policy

          Federal agencies must provide reasonable accommodation to applicants with disabilities where appropriate. Applicants requiring reasonable accommodation for any part of the application process should follow the instructions in the job opportunity announcement. For any part of the remaining hiring process, applicants should contact the hiring agency directly. Determinations on requests for reasonable accommodation will be made on a case-by-case basis.

          A reasonable accommodation is any change to a job, the work environment, or the way things are usually done that enables an individual with a disability to apply for a job, perform job duties or receive equal access to job benefits.

          Under the Rehabilitation Act of 1973, federal agencies must provide reasonable accommodations when:
          • An applicant with a disability needs an accommodation to have an equal opportunity to apply for a job.
          • An employee with a disability needs an accommodation to perform the essential job duties or to gain access to the workplace.
          • An employee with a disability needs an accommodation to receive equal access to benefits, such as details, training, and office-sponsored events.

            You can request a reasonable accommodation at any time during the application or hiring process or while on the job. Requests are considered on a case-by-case basis.

            Learn more about or

            Legal and regulatory guidance
            • Financial suitability
            • Social security number request
            • Privacy Act
            • Signature and false statements
            • Selective Service
            • New employee probationary period

Keywords: The Department of the Treasury, Laguna Niguel , Tax Law Specialist (International Transfer Pricing Specialist), Accounting, Auditing , Laguna Niguel, California

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