Attorney-Advisor (Tax) - Special Counsel (INTL), Portland

Attorney-Advisor (Tax) - Special Counsel

The Special Counsel serves as the legal and technical consultant to the Associate and Deputy Associate Chief Counsels (International) (INTL), on the most difficult, important and complex matters. INTL's responsibilities include legal issues arising out of taxation of U.S. persons with foreign activities (foreign tax credits; taxation of income earned through direct or passive investments, controlled and non-controlled foreign corporations, passive foreign investment companies, unincorporated branch operations and foreign partnerships or trusts; and information reporting obligations), the taxation of foreign persons with U.S. activities (effectively connected income, branch profits tax, determination of U.S. residence and consequences of expatriation, withholding of tax on U.S. source income, the taxation of foreign governments and international organizations and their employees), U.S. taxation relating to U.S. territories, and laws relating to cross-border activities of both domestic and foreign persons (transfer pricing; entity classification; cross-border reorganizations; the source of income and allocation of deductions); taxation of financial products and income from international financial services and insurance activities; foreign currency transactions; international information exchange and summons enforcement; conflict of laws and the application of income tax treaties and international agreements. As an Attorney-Advisor (Tax) - Special Counsel, your duties will include the following:Operate as a critical link between subject matter experts in INTL and other Counsel offices, as well as personnel in Appeals and Examination, with respect to the preparation of technical guidance, international field service, litigation, and strategic programs. Draft both legal and non-legal documents ranging from tax advocacy designed for legal practitioners to non- technical/educational materials targeted for more general use. Provide oral and written advice applying the tax laws related to cross-border transactions and activities, including the international provisions of the U.S. revenue laws, and bilateral and multilateral tax treaties and agreements to which the United States is a party. Exercise decision-making skills, including in case or project management. Analyze and interpret complex tax legislation, regulations, and policy matters that impact international tax policies and guidance.Ensure that controversies stemming from cross-border transactions and activities are handled consistently with the correct interpretation of international provisions of the United States revenue laws, bilateral and multilateral tax treaties and agreements to which the United States is a party, and all foreign revenue laws that pertain to or affect tax matters in the United States.Render legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning international issues under examination in the audit of returns or in the consideration of claims for refunds or in respect of matters of treaty interpretation; and participate in the preparation of briefs and other materials in connection with U.S. Tax Court litigation involving international matters.Prepare or review recommendations concerning the defense, settlement, concession, or appeal of refund suits pending in international cases in the U.S. District Courts or the U.S. Court of Federal Claims; and work with the Department of Justice in connection with preparation of briefs and positions and strategy taken in international appellate litigation.This is not an all-inclusive list.