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Internal Revenue Service is Hiring a Competent Authority Analyst (12 Month Roster) Near Glendale, CA

Qualifications:

Federal experience is not required. The experience may have been gained in the public sector, private sector or Volunteer Service. 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.

You must meet the following requirements by the closing date of this announcement:


In addition to meeting the basic requirement above, to qualify for this position you must also meet the qualification requirements listed below:

SPECIALIZED EXPERIENCE: GS-14 LEVEL: To be eligible for this position at the GS-14 grade level, you must have at least one year of specialized experience equivalent to the GS-13 grade level. Specialized experience is experience that has equipped you with the particular knowledge, skills, and abilities to perform successfully the duties of the position, and that is typically in or related to the work of the position to be filled. Specialized experience is such that demonstrates experience in methods and techniques pertaining to the interpretation and application of U.S. transfer pricing regulations, and to analyze and provide assistance to taxpayers requesting relief from double taxation related to transfer pricing adjustments; experience with U.S. transfer pricing regulations and the Organization for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines; experience in applying IRS Revenue Procedures covering requests for relief and the prevention of double taxation and other policies and procedural guidelines relating to competent authority matters; and experience with the Internal Revenue Code and regulations pertaining to transfer pricing to analyze and provide assistance to taxpayers requesting relief from double taxation.

OR
COMBINATION OF EXPERIENCE AND EDUCATION: You may qualify by a combination of experience and education. Options for qualifying based on a combination will be identified in the online questions.

AND

TIME AFTER COMPETITIVE APPOINTMENT: By the closing date (or if this is an open continuous announcement, by the cut-off date) specified in this job announcement, current civilian employees must have completed at least 90 days of federal civilian service since their latest non-temporary appointment from a competitive referral certificate, known as time after competitive appointment. For this requirement, a competitive appointment is one where you applied to and were appointed from an announcement open to 'All US Citizens'.



For more information on qualifications please refer to OPM's Qualifications Standards.

Responsibilities:

WHAT IS THE LARGE BUSINESS AND INTERNATIONALDIVISION?
A description of the business units can be found at: https://www.jobs.irs.gov/about/who/business-divisions

Vacancies will be filled in the following specialty areas:
Treaty and Transfer Pricing Operations - APMA

WHAT DOES A COMPETENT AUTHORITY ANALYST (APMA TEAM LEADER) DO? This position seeks tax professionals who will primarily perform the duties of an Advance Pricing and Mutual Agreement (APMA) Team Leader within the office of the U.S. Competent Authority and is part of Treaty and Transfer Pricing Operations (TTPO) in the Large Business & International (LB&I) division of the IRS. APMA's mission is to resolve actual or potential transfer pricing disputes and other competent authority matters under the mutual agreement procedures of the United States' bilateral income tax conventions. APMA team leaders possess substantial skill in international tax provisions of the Internal Revenue Code (Section 482) relating to transfer pricing with advanced knowledge of relevant provisions in U.S. income tax treaties (e.g., Articles 7, 9 and 25), the Organization for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines, and foreign transfer pricing rules.

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.
• Leads and works cooperatively within teams of IRS employees (notable international examiners, economists, and attorneys) and independently develops facts, issues, analysis, and conclusions as needed. Secures additional information directly from taxpayers or from treaty partners in furtherance of these goals when necessary.

Job Summary