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 Senior Counsel serves as a legal expert on matters under the jurisdiction of the Office of the Associate Chief Counsel (International) (INTL), acting as consultant to the Branch Chief and other branch managers, and the Associate and Deputy Associate Chief Counsels. 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. INTL 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 Counsel for one of INTL's seven branches, you will have the following responsibilities in your assigned branch: Perform technical review of some of the office's most complex, important or novel case/project assignments, particularly those with broad or potentially controversial ramifications. Independently plan, develop, and complete complex legal work products without review, and provides technical guidance and review of other staff work products. Serve as team leader on large-scale INTL guidance and publication projects that may include representatives from other Counsel Divisions or IRS offices. Direct and coordinate work of other team members and oversees all related administrative and logistical matters. Research complex issues and trends affecting INTL legal services and determines likely legal ramifications on INTL programs. Ensure the legal or administrative consequences of potential actions to handle these issues are fully considered and write decision papers to determine Counsel's position on these matters. Prepare final comments/recommendations on behalf of the office. Identify the need for, develop and draft new procedures and regulations to implement, new or amended legislation to ensure that policies are consistent with the intent of the law and are administratively sound and economical in operation and to enable INTL to effectively meet its mission. This is not an all-inclusive list.
Salary
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) - Senior Counsel you must meet the qualification requirements listed below by the closing of this announcement: Basic Requirements for General Attorney (Tax) - Senior 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 year(s) of professional legal tax experience Professional Legal Tax Experience is defined as: Significant knowledge related to the development, interpretation, and administration of the international tax provisions of the Internal Revenue Code, including experience in one or more of the following areas: tax treaties, international tax rules affecting individuals, and withholding taxes; anti-deferral provisions, such as subpart F, the GILTI regime, and passive foreign investment companies; foreign tax credits and sourcing of income; cross-border mergers and acquisitions and international tax aspects of partnerships; international tax issues related to banking, financial products, and insurance; transfer pricing and FDII; exchange of information, other information gathering, and issues related to territories. 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) 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. Time in Grade Requirement for GS-15: Applicants who have held a General Schedule (GS) position within the last 52 weeks must have 52 weeks of Federal service at the next lower grade or equivalent (GS-???????14).
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).
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: An unofficial or official transcript(s) for your J.D. degree or LL.M. degree (an official transcript is required if you are selected). Transcripts must show the date the degree/certification was conferred/awarded. Failure to do so will result in your removal from consideration. 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 A memorandum of interest summarizing your interest in the position 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. Employment Documentation: Submit a copy of your most recent SF-50, Notification of Personnel Action, which shows your current (or most recent) grade. 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.
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 10/23/2025 and/or cut-off dates in this announcement. We are available to assist you during business hours (normally 8:00-4:30 ET, Monday - Friday). To preview the Application Questionnaire, please click the following link: https://apply.usastaffing.gov/ViewQuestionnaire/12814482 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 503-265-3841 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.
