General Attorney (Tax) - Senior Technician Reviewer (INTL), Sacramento

Associate Office Of Chief Counsel, International

The responsibilities of the Associate Office of Chief Counsel, International, 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. The Office has seven branches, each with expertise in and subject matter jurisdiction over one or more of the above areas. As a General Attorney (Tax) - Senior Technical Reviewer for one of the Office's seven branches, you will have the following responsibilities in your assigned branch:Act as a legal and technical consultant to the Branch Chief, the Deputies Associate Chief Counsel (International), the Associate Chief Counsel (International), and, as assigned, to other officials in the Office of Chief Counsel on some of the most important professional legal and policy matters concerned with the work of the Branch, or that may affect the work of other Branches of the office, or other components of the Office of Chief Counsel. Such matters involve research on complicated legal problems and the development of recommendations regarding the positions to be taken by the Branch and the Office.Act as a reviewer, and in some cases as the initiating attorney on projects involving the development and drafting of Internal Revenue legislation and regulations, considering recommendations for enactment of legislation and the promulgation of regulations, and the issuance of private letter rulings, revenue rulings, technical advice memoranda, general legal advice memoranda, and other guidance.Act as the principal attorney in charge of recommending the policies and developing the procedures and regulations implementing new or amended legislation for specific areas of tax law and is responsible for ensuring that these policies, procedures, and regulations are consistent with the intent of the law and are administratively sound, efficient, and economical in operation.Perform activities in the subject area of the Branch including legal assistance, document review, appellate recommendations, and litigation support. Many of the issues presented for decision are submitted after extensive consideration in the field and elsewhere. Problems presented cover a broad range of tax law issues requiring interpretation of the Internal Revenue Code, tax regulations, published rulings, court cases, and other technical materials. Make recommendations on the need for initiating, consolidating, or eliminating programs and projects. Act as project manager, assigns (in consultation with the Branch Chief) work to the attorneys and specialists within the Branch, advises them on the approach to take, reviews work product, and provides the Branch Chief with performance feedback of work performed.Represent the IRS in conferences with taxpayers and their representatives. In this connection, the STR analyzes the transactions or issues involved in light of the Internal Revenue Code and applicable regulations, examines the data submitted (such as court exhibits and briefs), questions taxpayers or their representatives, and makes a determination or recommendation for the IRS.Participate in the resolution of complex technical problems presented by taxpayers or their representatives and give advice on important technical, legal, and policy matters to the Associate Chief Counsel (International), the Deputies Associate Chief Counsel (International), and other Office of Chief Counsel officials.Speak or engage in panel discussions before business and professional groups on technical and legal matters relating to the work of the Branch. This is not an all-inclusive list.