General Attorney (Tax) - Senior Counsel - International

We are seeking a highly experienced General Attorney (Tax) to serve as Senior Counsel, specializing in complex international tax law matters. This role requires a deep understanding and significant experience with the Internal Revenue Code's international provisions.

• *Key Responsibilities:**
• Interpret and administer international tax provisions of the Internal Revenue Code.
• Provide expertise in areas such as tax treaties, international rules for individuals and withholding taxes.
• Address anti-deferral provisions (Subpart F, GILTI, PFICs) and foreign tax credits.
• Handle income sourcing, cross-border mergers & acquisitions, and international partnership tax issues.
• Work on international tax matters related to banking, financial products, insurance, transfer pricing, and FDII.
• Manage exchange of information, information gathering, and territory-related tax issues.
• *Qualifications:**
• *Basic Requirements:**
• **Education:** Juris Doctor (J.D.) or Bachelor of Laws (LL.B.) degree from an American Bar Association (ABA) accredited law school.
• **Bar Membership:** Active member in good standing of the bar of a U.S. State, U.S. Commonwealth, U.S. Territory, the District of Columbia, or Puerto Rico.
• *Experience (Post-Bar Admission):**
• **Total Legal Experience:** A minimum of 4 years of professional legal experience gained after Bar admission, including:

* At least 1 year of general professional legal experience. * At least 3 years of specialized professional legal tax experience.

• **Specialized Tax Experience:** Significant knowledge and experience in the development, interpretation, and administration of international tax provisions of the Internal Revenue Code, covering areas such as:

* Tax treaties, international tax rules affecting individuals, and withholding taxes. * Anti-deferral provisions (e.g., Subpart F, GILTI, PFICs). * Foreign tax credits and income sourcing. * Cross-border mergers & acquisitions, international tax aspects of partnerships. * International tax issues in banking, financial products, and insurance. * Transfer pricing and FDII. * Exchange of information and related territory issues.

• **Federal Service Requirement (GS-15):** At least one year of experience must be equivalent to the GS-14 level in the federal service. (Applicants currently in federal service must have 52 weeks at GS-14 within the last 52 weeks.)
• *Education Substitution:**
• An LL.M. degree in Tax may substitute for the 1 year of general professional legal experience.
• *Note:** All professional legal experience must be gained after Bar admission. Volunteer experience that is relevant will be credited.