Competent Authority Analyst (APMA Project Leader)

About the role

WHAT IS LARGE BUSINESS & INTERNATIONAL? A description of the business units can be found at: https://www.jobs.irs.gov/about/who/business-divisions Position(s) are to be filled in the following area(s): LBI - Director Treaty and Trans Pric Ops - Advanced Practice and Mutual Agreements Consider each location carefully when applying. If you are selected for a location, that location will become your official post of duty. REVIEW THE ADDITIONAL INFORMATION BELOW FOR FURTHER DETAILS

What you'll do

The following are the duties of this position at the full working level. If this vacancy includes more than one grade and you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and receive training to help you grow in this position. Reviews Advance Pricing Agreement (APA) requests and taxpayer requests for assistance in obtaining relief from double taxation to determine if such requests comply with procedural guidelines. Performs a balanced and critical analysis of taxpayer and treaty partner proposals and performs due diligence to ensure that the facts and circumstances of the taxpayer's case are sufficiently understood to arrive at a legally supportable determination. Evaluates, analyzes, and develops the positions of the United States with respect to complex transfer pricing issues and other international tax issues. Leads IRS projects to determine the best transfer pricing method and position to adopt in a given case in a timely manner.

Qualifications

Federal experience is not required. Experience may have been gained in the public sector, private sector or through Volunteer Service. One year of experience refers to full-time work; part-timework is considered on a prorated basis. To ensure full credit for your work experience, please indicate dates of employment by month/day/year, and indicate number of hours worked per week, on your resume. You must meet the following requirements by the closing date of this announcement. SPECIALIZED EXPERIENCE GS-14: To be eligible for this position, you must have one (1) year of specialized experience at a level of difficulty and responsibility equivalent to the GS-13 grade level in the Federal service. Specialized experience includes: Experience interpreting and applying U.S. tax treaties to analyze taxpayer requests for relief from double taxation or taxation inconsistent with treaty provisions and advising taxpayers, Internal Revenue Service personnel, treaty partners, or other stakeholders on treaty-related issues; Experience analyzing and interpreting Internal Revenue Code section 482, implementing regulations, and related legal decisions and applying Revenue Procedures 2015-40 and 2015-41 to competent authority and advance pricing agreement matters; Experience analyzing and interpreting U.S. tax treaties, the U.S. Model Income Tax Convention, the Organization for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and the OECD Model Tax Convention on Income and on Capital to develop positions on transfer-pricing and double-taxation matters; and Experience applying the Internal Revenue Code and implementing regulations to analyze international tax issues arising from tax planning or examinations of multinational enterprises. AND You must also meet the following requirements: MINIMUM AGE REQUIREMENT: Minimum age for federal employment is 18 years old, or at least 16 years old and have: Graduated from high school or been awarded a certificate equivalent to graduating from high school; or Completed a formal vocational training program; or Received a statement from school authorities agreeing with your preference for employment rather than continuing your education. For more information on qualifications please refer to OPM's Qualifications Standards.

Requirements

Probationary Period - All newly appointed employees to the competitive (or excepted) service are subject to a probationary (or trial) period. During this time, your performance, conduct, and suitability for continued employment will be evaluated. You will not automatically convert to permanent status at the end of the probationary (or trial) period. Your supervisor must affirmatively determine that continued employment is in the best interest of the Federal service. If no certification is made before the probationary (or trial) period ends, your appointment will be terminated. You are encouraged to actively engage with your supervisor, seek feedback, and understand role expectations. Additional guidance and support will be provided during onboarding. Government Credit Card - Obtain and use a Government-issued charge card for business-related travel. Traveling outside the United States may also be required. For overseas travel, will be required to obtain an official United States Passport. Tax Audit - 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. Key Eligibility Requirements: U.S Citizenship - Must be a U.S. Citizen or National and provide proof of U.S. Citizenship. Selective Service Registration - Males born after December 31, 1959 are required to be registered with the Selective Service System or prove they are exempt from having to do so. Personal Identity Verification (PIV) - Must provide 2 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. These documents must be unexpired original or certified copies. ADDITIONAL REQUIREMENTS SHOWN IN QUALIFICATIONS OR ADDTIONAL INFORMATION SECTIONS

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