Paul L. Caron

Tuesday, May 18, 2021

IRS Seeks To Hire Five Transfer Pricing Attorneys

The IRS Large Business & International Division (LB&I) seeks to hire five transfer pricing attorneys (salary: $108,885 to $162,753) among these twelve locations:

  • IRS Logo 2Denver, CO
  • Chicago, IL
  • Downers Grove, IL
  • Schiller Park, IL
  • Indianapolis, IN
  • Farmington Hills, MI
  • Grand Rapids, MI
  • Bloomington, MN
  • Cincinnati, OH
  • Columbus, OH
  • Tulsa, OK
  • Houston, TX

The Transfer Pricing Practice (TPP) is part of Treaty and Transfer Pricing Operations (TTPO) in the Large Business & International (LB&I) division of the IRS. Transfer pricing essentially involves the pricing of goods, services, and intellectual property transferred between related entities of multinational enterprises (typically corporations with a common parent company). When these transactions involve related entities located in foreign countries, tax issues arise over how much income should be reported in each country. The United States and foreign tax administrations have complex tax rules about how intercompany pricing is to be determined and income reported. It is an area of significant tax controversy, not only in the United States, but also in numerous countries around the world.

The IRS Transfer Pricing Practice conducts many types of compliance activities related to transfer pricing. Those activities include examination cases, Compliance Assurance Process (CAP) cases, Campaigns (which may or may not include examinations), assisting with Advance Pricing Agreement matters, and other efforts. The Practice Network supports those working on transfer pricing issues in TTPO by performing risk assessments and identifying emerging issues or issues of strategic importance. In addition, the Practice Network develops training in transfer pricing issues, provides advice to campaigns and assists agents in transfer pricing tax examinations.

The following are the duties of this position at the full working level. If you are selected at a lower grade level, you will have the opportunity to learn to perform these duties and will receive training to help you grow in this position.

  • Assists Examination Teams in planning, directing, and coordinating the examination of international transfer-pricing issues. The incumbent serves on a consulting basis for other Examination Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents assigned to a Coordinated Industry or Industry Examination regarding transfer-pricing issues and transactions. The incumbent may also be assigned to work closely with IRS Examination Teams on multiple examinations simultaneously.
  • Collaborates and coordinates with Examination Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents to leverage and expand international issue expertise throughout the IRS, and to ensure consistent application and interpretation of international tax law. The incumbent regularly participates in groups focused on international issues including, but not limited to, International Practice Networks (IPNs)
  • Participates in long-term projects involving the development of new auditing techniques, work practices, and training programs for Examination Specialists, International Examiners, Counsel Attorneys, Appeals Officers, and Revenue Agents. The incumbent develops and conducts training sessions and holds periodic meetings with IRS personnel at national and local office levels to review all matters relating to international transfer-pricing.
  • Performs research and analysis of tax issues involving economics, transfer pricing, and valuation related to specific taxpayers or across taxpayers and industries.
  • Provides feedback, technical expertise, and recommendations to IRS management and IRS Counsel on transfer-pricing issues. The International Transfer Pricing Specialist identifies and discusses any issues that require technical advice, field service advice, or industry-wide coordination procedures to be followed.

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