Associate Chief Counsel (PTE)

Created at: August 30, 2025 00:16

Company: Internal Revenue Service

Location: Washington, DC, 20001

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
To qualify for this position of Associate Chief Counsel (PT&E) you must meet the following requirements: 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; Desired Education/Experience: An LL.M. in Taxation is desired but not required. Seven (7) years of professional legal tax experience is desired. As a basic requirement for entry into the SES, applicants must provide evidence of progressively responsible executive leadership and supervisory experience that is indicative of senior executive level managerial capability. The ideal candidate will have experience supervising many employees through subordinate supervisors and have experience hiring, developing, and evaluating employees. Typically, experience of this nature is at the GS-15 or equivalent level in the federal service or its equivalent in the private sector. To meet the minimum qualifications, you must submit a two-page resume that shows you possess the five Executive Core Qualifications (ECQs) and Technical Qualifications (TQs). To be considered, the resume must not exceed two pages. If selected for this position you will be required to address each ECQ during a structured interview with the Office of Personnel Management (OPM) Qualifications Review Board (QRB). Written narratives for the ECQs are not required. Current and former career SES employees, and OPM Candidate Development Program (CDP) graduates are exempt to address the ECQs. By statute, OPM prescribes Executive Core Qualifications (ECQs) for the appointment of career SES members. The ECQs were designed to evaluate executive experience and not technical expertise. The following ECQs provide the focus for certification of executive core qualifications for initial appointment to the Senior Executive Service. Your two-page resume should show that you possess the Executive Core Qualifications listed below: Commitment to the Rule of Law and the Principles of the American Founding: This core qualification requires a demonstrated knowledge of the American system of government, commitment to uphold the Constitution and the rule of law, and commitment to serve the American people. Driving Efficiency: This core qualification involves the demonstrated ability to strategically and efficiently manage resources, budget effectively, cut wasteful spending, and pursue efficiency through process and technological upgrades. Merit and Competence: This core qualification involves the demonstrated knowledge, ability and technical competence to effectively and reliably produce work that is of exceptional quality. Leading People: This core qualification involves the demonstrated ability to lead and inspire a group toward meeting the organization's vision, mission, and goals, and to drive a high-performance, high- accountability culture. This includes, when necessary, the ability to lead people through change and to hold individuals accountable. Achieving Results: This core qualification involves the demonstrated ability to achieve both individual and organizational results, and to align results to stated goals from superiors. Additional information on ECQs is in OPM's Guide to SES Qualifications. Applicants are strongly encouraged to follow the Challenge, Context, Action and Results model outlined in the guide, to prepare for the structured interview. Written narratives for the ECQs are not required; however, applicants must be prepared to address each ECQs in a structured interview with the QRB. In addition to the ECQs, candidates must address Technical Qualifications (TQs). TQs are designed to assess an applicant's experience relevant to the specific position requirements. All applicants must clearly demonstrate in their two-page resume, experience and accomplishments related to the TQs below: TECHNICAL QUALIFICATIONS (TQs): Demonstrated ability to develop nationwide strategies and provide dedicated support and legal advice to high profile significant IRS top ranking officials and provide effective quality legal services to both internal and external customers. Demonstrated comprehensive, professional knowledge of and experience in applying tax laws affecting passthrough entities and activities, classification of domestic and foreign entities, and issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift and generation skipping taxes. Desirable: A thorough understanding of the operations and organization of the Internal Revenue Service and Office of Chief Counsel. 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.
As a key member of the executive staff of the Chief Counsel, the Associate Chief Counsel, Passthroughs, Trusts and Estates (PT&E) is responsible for coordinating and directing all activities of the Associate Office for PT&E within the Office of Chief Counsel, Internal Revenue Service (IRS). The Associate Office of PT&E (Office) provides legal advisory services that support the uniform interpretation, application, enforcement, and litigation of tax laws involving a wide range of business and investment entities. The Office manages the classification of domestic and foreign entities and issues involving passive activity and at risk loss limitations, tax shelter disclosures, and estate, gift, and generation skipping taxes (referred to collectively as "transfer taxes") and with Treasury officials and IRS Division Commissioners and other Associate and Division Counsel on program matters, such as identifying and prioritizing emerging issues and publishing guidance. As the Associate Chief Counsel (PT&E), you will: Serve as the principal legal advisor to the IRS and the Office of Chief Counsel on matters relating to passthrough entities and transfer taxes, publishes public and other technical guidance on such issues, and shares responsibility with the Division Counsel for the direction and oversight of the Counsel-wide litigation program involving passthrough entities and transfer taxes. Represent the IRS and Treasury on sensitive and controversial issues related to these areas. Formulate and direct programs and policies with respect to litigation involving passthrough entities and transfer taxes in the U.S. Tax Court. Assures IRS-wide consistency of approach in tax litigation involving passthrough entities and transfer taxes; consult with the Division Counsel as to the defense or settlement of cases pending in U.S. Tax Court (including the preparation and approval of Chief Counsel actions on decisions) and, review and coordinate pleadings, briefs, settlement documents, notices of appeal, and other materials prepared in connection with U.S. Tax Court litigation involving passthrough entities and transfer taxes. Provide executive direction to staff engaged in drafting revenue rulings, revenue procedures, 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; issue private letter rulings and general technical information letters in response to requests from taxpayers; and prepare Chief Counsel Advice and other legal opinions for other Chief Counsel offices and IRS functions with respect to legal questions raised in litigation and IRS programs. Work with Treasury officials to coordinate recommendations for legislation that particularly affects matters involving passthrough entities and transfer taxes; direct 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; oversee IRS participation with legislative staffs in the drafting of such legislation and committee reports. Coordinate the processing and review of nondocketed cases submitted for consideration by various local, area, division, or national levels. Renders legal advice and assistance to IRS personnel and other Chief Counsel personnel concerning issues involving passthrough entities and transfer taxes under examination in the audit of returns, or in the consideration of claims for refund. Develop and monitor performance measures and program goals for the provision of legal services and published guidance, and the implementation, compliance, and outreach initiatives on issues involving passthrough entities and transfer taxes. Plan, direct, and coordinate nationwide programs relating to passthrough entities and transfer taxes, including with respect to all personnel, fiscal and budgetary requests and recommendations. Balance the diverse needs of program segments and determine the allocation and deployment of human and fiscal resources that best positions the organization to meet the needs of clients as a whole. Direct and oversee the overall management of the division's legal staff. Ensure all management functions are handled equitably and in a manner that is responsive to the needs of all programs that the division supports. Ensure sound position management policy. Take positive steps in support of all merit system principles. Perform other duties as assigned.


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