Economist

Strategic Litigation Division Counsel Position

The Strategic Litigation (SL) Division Counsel is a national organization with approximately 90 attorneys and 30 paralegals located in 33 cities nationwide. The SL Division, through its Special Trial Attorneys and paralegals, is responsible for handling the Office of Chief Counsel's most complex, high-profile, and significant cases in the United States Tax Court, which cases often establish national precedent or are otherwise important to tax administration. The SL attorneys and paralegals provide a full range of legal services on all issues, including advising the Internal Revenue Service on its most significant non-docketed cases, handling significant case litigation in the United States Tax Court, and assisting the Department of Justice in the handling of significant cases in both Federal and State Courts.

As an Economist, you will:

• Responsible for providing trial preparation and consultative support to SL trial attorneys handling Tax Court litigation and other Federal Court litigation activities involving the most complex, significant, and difficult cases with nationwide, often precedent-setting impact before the U.S. Tax Court and other Federal Courts.
• Required to use expert economic and subject-matter knowledge, including but not limited to, statistics, valuation, and transfer pricing (based on the principles set forth in I.RC.§ 482 and the Organization for Economic Cooperation and Development (OECD) Transfer-Pricing Guidelines for Multinational Enterprises and Tax Administrations), and exercise sound judgment and independence.
• Provides consultative support to SL trial attorneys on the most complex technical issues requiring incumbent's personal in-depth knowledge, originality, deep technical background, experience, and creativity.
• Performs research and analysis of tax issues involving economics, statistics, valuation, and/or transfer pricing, related to specific taxpayers and industries applicable to the assigned cases being litigated before the Tax Court or other Federal Courts.
• Reviews economic, statistical, and subject-matter literature for data and research methodology appropriate for inclusion in the research. In transfer-pricing cases, evaluates the reasonableness of the parties' transfer-pricing positions to the litigation, and, as applicable, may evaluate the reasonableness of foreign tax jurisdiction positions.

This is not an all-inclusive list.