Job Description
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 Associate Chief Counsel (Corporate) (ACC (CORP)) is a key member of the Chief Counsel executive staff. The ACC (CORP) serves as the principal legal advisor to the Internal Revenue Service (IRS) and the Office of Chief Counsel, on all matters relating to the tax consequences of transactions between corporations and between corporations and their shareholders, and matters that involve affiliated groups of corporations filing consolidated returns, creation of corporations, mergers and acquisitions, dividends, distributions in redemption of stock, liquidations, spin-offs, corporate debts and bankruptcies, and limitations on losses. The ACC (CORP) provides executive direction on all activities of the CORP organization, which consists of approximately 60 professional and support employees in the Washington, D.C. Headquarters. The incumbent works closely with Treasury officials and IRS Division Commissioners and other Associate and Division Counsel (DC) on program matters (e.g., identifying and prioritizing emerging issues) and with IRS Division Commissioners, other Associate and Division Counsel, and Department of Justice officials, on matters involving tax litigation. As an Associate Chief Counsel, major duties include: Shares responsibility with Division Counsel for the direction and oversight of the Counsel-wide administrative controversy and litigation programs involving corporate tax issues and represents the IRS and Treasury on sensitive and controversial issues related to these areas. Formulates and directs programs and policies with respect to litigation of CORP issues in the U.S. Tax Court, and together with DC, makes determinations as to which of such cases should be tried, settled, and conceded. Assures IRS-wide consistency of approach in corporate tax litigation; consults with the DC as to the defense or settlement of corporate tax cases pending in U.S. Tax Court (including the preparation and approval of Chief Counsel decisions) and, together with the DC, reviews and coordinates pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S. Tax Court litigation involving corporate tax issues. Except with respect to certiorari matters, approves recommendations of acquiescence and non-acquiescence in adverse decisions, and orders in such cases and suits and makes recommendations to the Department of Justice (DOJ) regarding appeals, offers in compromise, or settlement in such cases or suits pending on appeal. Directs preparation of recommendations concerning defense, settlement, or concession, and authorizes or sanctions counterclaims, third-party complaints, or the commencement of collection suits with respect to refund suits pending in corporate tax cases in the U.S. District Courts or the Court of Federal Claims. Coordinates appellate litigation with the General Counsel and Commissioner of Internal Revenue, as appropriate. In collaboration with Treasury officials, provides executive direction to staff engaged in drafting revenue rulings, revenue procedures, notices, announcements, and news releases to be published for the guidance of taxpayers and IRS personnel; issuing technical advice memoranda responding to questions raised by IRS examiners; issuing private letter rulings and general technical information letters in response to requests from taxpayers; and preparing legal opinions for other Chief Counsel offices and IRS functions with respect to legal questions raised in litigation and IRS programs. In collaboration with Treasury officials, coordinates recommendations for legislation that particularly affects CORP activities; directs IRS participation in this aspect of the legislative process, including the furnishing of advice and guidance with respect to the development of new or revised legislative proposals. Salary- $150,160 - $225,700/year