General Attorney (Tax) - Special Counsel (Passthroughs, Trusts, and Estates)

Office of Chief Counsel, IRS, seeks enthusiastic individuals to serve taxpayers fairly and with integrity by providing correct and impartial interpretation of the internal revenue laws and the highest quality legal advice and representation for the IRS. To learn more, click the links below: IRS Office of Chief Counsel Careers Site Meet Our People Learn about our Legal Divisions

Duties

The Special Counsel serves as legal and technical consultant for the Associate Chief Counsel Passthroughs, Trusts and Estates (PT&E) on tax matters involving passthrough entities (partnerships, S corporations, and trusts) and on transfer tax issues (estate, gift, and generation-skipping transfer taxes).

As a General Attorney (Tax) - Special Counsel, you will:

• Serve as a legal and technical consultant and confidential advisor to the Associate Chief Counsel (PT&E) and the Deputy Associate Chief Counsel (PT&E)
• Assist in the preparation and review of technical guidance, including regulations, sub-regulatory guidance
• Coordinate the technical review of legislative proposals
• Serve as the team leader/project manager on large scale guidance projects
• Operate as a critical link between subject-matter experts in PT&E and other offices within the Office of Chief Counsel and the IRS
• Ensure that controversies stemming from transactions and activities under PT&E's jurisdiction are developed and handled consistently with the correct legal interpretation of the relevant provisions of the Internal Revenue Code and associated regulations
• Provide legal advice and assistance in the preparation and review of recommendations concerning the defense, settlement, concession, or appeal of refund suits pending in cases in the U.S. District Courts or the U.S. Court of Federal Claims
• Represent PT&E as a speaker before national associations or professional groups for the purpose of furthering, advancing, and explaining the positions of the Office of Chief Counsel, the IRS, and the Department of the Treasury.

This is not an all-inclusive list.

Salary

• $167,603 - $195,200/year

Conditions of Employment

• Refer to "Additional Information"
• Click "Print Preview" to review the entire announcement before applying.
• Must be a U.S. Citizen or National

Qualifications

In order to qualify, you must meet the education and/or experience requirements detailed below by the closing date of this announcement. Your resume must clearly describe your relevant experience; if qualifying based on education, your transcripts will be required as part of your application.

To qualify for this position of General Attorney (Tax) - Special Counsel, you must meet the qualification requirements listed below by the closing of this announcement:

Basic Requirements for General Attorney (Tax) - Special Counsel:

• Possess at least the first professional law degree (LL.B. or J.D.) from a law school accredited by the American Bar Association; AND
• Applicants must be an active member in good standing of the bar of a State, U.S. Commonwealth, U.S. territory, the District of Columbia, or the Commonwealth of Puerto Rico;

GS-15 Experience Requirements:

• 1 year of general professional legal experience from any area of expertise; plus
• 3 years of professional legal tax experience

Professional Legal Tax Experience is defined as: Providing legal guidance and analysis related to Internal Revenue tax laws, regulations, and decisions applicable to:

• Passthrough entities (including sole proprietorship, partnership, LLC, S Corp);
• Trusts (including revocable trust, irrevocable trust under);
• Estate and gift transfer taxes under § 2501; AND/OR
• Tax litigation and procedure.

At least one year of this experience must be equivalent to the work performed at the next lower grade/level position in the federal service (GS-14). Note: Only experience gained after Bar Admission may be credited as Professional Legal Experience.

Education Substitution: An LL.M. degree in the field of the position (tax, GLS-related, orP&A- FOIA/Disclosure related field) may be substituted for the one year of the general legal experience listed above.

Experience refers to paid and unpaid experience, including volunteer work done through National Service programs (e.g., Peace Corps, AmeriCorps) and other organizations (e.g., professional; philanthropic; religious; spiritual; community; student; social). You will receive credit for all qualifying experience, including volunteer experience. 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.

Education For positions with an education requirement, or if you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. 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 Department of Education Accreditation page. FOREIGN EDUCATION: If you are using education completed in foreign colleges or universities to meet the qualification requirements, you must show the education credentials have been evaluated by a private organization that specializes in interpretation of foreign education programs and such education has been deemed equivalent to that gained in an accredited U.S. education program; or full credit has been given for the courses at a U.S. accredited college or university. If you are qualifying based on foreign education, you must submit proof of creditability of education as evaluated by a credentialing agency. For further information, visit: Recognition of Foreign Qualifications | International Affairs Office (ed.gov) Other Information We may select from this announcement or any other source to fill one or more vacancies. Relocation expenses are not authorized. This is a non-bargaining unit position. We offer opportunities for telework. We offer opportunities for flexible work schedules. Conditions of Employment Continued: Subject to a 1-year trial period (unless already completed). Subject to a Tenure Commitment of up to 3 years 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. Have your salary sent to a financial institution of your choice by Direct Deposit/Electronic Funds Transfer. 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. Obtain and use a Government-issued charge card for business-related travel. File a Confidential Financial Disclosure Report within 30 days of appointment and annually from then on. Undergo an income tax verification. 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. This position requires that the successful candidate undergo personnel vetting, which includes a background investigation and enrollment upon onboarding into "Continuous Vetting." Enrollment in Continuous Vetting will result in automated record checks being conducted throughout one's employment with Treasury. The successful candidate will also be enrolled into FBI's Rap Back service, which will allow Treasury to receive notification from the FBI of criminal matters (e.g., arrests, charges, convictions) involving enrolled individuals in near real-time. There are three key documents that contain important information about your rights and obligations. Please read and retain these documents: Noncriminal Justice Applicant's Privacy Rights, for those who undergo an FBI fingerprint-based criminal history record check for personnel vetting, which includes Rap Back, FD-258 Privacy Act Statement - FBI (this is the same statement used when your fingerprints are submitted as part of your background investigation), and SEAD-3-Reporting-U.pdf (dni.gov), (applicable to those who hold a sensitive position or have eligibility for access to classified information) 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 may 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. (Cover letters 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 resume tips.

In addition, applicants are required to submit:

1. An unofficial or official transcript(s) for your J.D. degree or LL.M. degree (an official transcript is required if you are selected)
2. A memorandum of interest summarizing your interest in the position

Current Chief Counsel Employees are also required to submit:

1. A copy of your most recent, signed, completed annual performance appraisal which includes the final rating. If it is not dated within the last 12 months or if you have not received a performance appraisal, please explain why in your application.
2. A Supervisory Report regarding your suitability for the position as completed by your current supervisor. You are responsible for notifying your supervisor that this report must be received no later than five workdays after the closing date of this announcement.

Education Documentation: For positions with an education requirement, or if you are qualifying for this position by substituting education or training for experience, submit a copy of your transcripts or equivalent. An official transcript will be required if you are selected. See "Education" for more details.

Certificate of Good Standing: A certified original copy of your certificate of good standing from your State Bar will be required if you are selected.

VETERANS' PREFERENCE DOCUMENTATION: There is no formal rating system for applying veterans' preference to attorney appointments in the excepted service; however, the Office of Chief Counsel considers veterans' preference eligibility as a positive factor in attorney hiring. If you are claiming veterans' preference, you must submit a copy of your Certificate of Release or Discharge from Active Duty, DD-214 (Member 4 copy), or other official documentation from a branch of the Armed Forces or the Department of Veterans Affairs showing dates of service and type of discharge. Ten-point preference eligibles must also submit an Application for 10-point Veteran Preference, SF-15, along with the required documentation listed on the back of the SF-15 form. For more information on veterans' preference, view FedsHireVets.

How to Apply

The following instructions outline our application process. You must complete this application process and submit any required documents by 11:59 p.m. Eastern Time (ET) on 09/26/2025 and/or cut-off dates in this announcement. We are available to assist you during business hours (normally 8:30am - 4:00pm ET, Monday - Friday). To preview the Application Questionnaire, please click the following link: https://apply.usastaffing.gov/ViewQuestionnaire/12795529

If you require a reasonable accommodation for a disability or medical condition during any part of the application and hiring process, please contact Kimberly Johnson, Reasonable Accommodation Coordinator, HR Labor & Employee Relations Division, by phone at 469-801-1728 or by email at Kimberly.F.Johnson@irscounsel.treas.gov. The IRS - Office of Chief Counsel provides reasonable accommodations to qualified applicants with disabilities on a case-by-case basis. You must contact us by 5:00 p.m. Eastern Standard Time on the announcement's closing date to request accommodation. If you are deaf, hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay services.

To begin, click Apply to access the online application. You will need to be logged into your USAJOBS account to apply. If you do not have a USAJOBS account, you will need to create one before beginning the application.

• Follow the prompts to select your resume and/or other supporting documents to be included with your application package. You will have the opportunity to upload additional documents to include in your application before it is submitted. Your uploaded documents may take several hours to clear the virus scan process.
• After acknowledging you have reviewed your application package, complete the Include Personal Information section as you deem appropriate and click to continue with the application process.
• You will be taken to the online application which you must complete in order to apply for the position. Complete the online application, verify the required documentation is included with your application package, and submit the application. You must re-select your resume and/or other documents from your USAJOBS account or your application will be incomplete.
• It is your responsibility to verify that your application package (resume, supporting documents, and responses to the questionnaire) is complete, accurate, and submitted by the closing date. Uploaded documents may take up to one hour to clear the virus scan.
• Additional information on how to complete the online application process and submit your online application may be found on the USA Staffing Applicant Resource Center.