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Competent Authority Analyst - DIRECT HIRE (6 Month Roster)
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- Large Business and International Director Treaty and Transfer Pricing Operations, APMA, TAIT
- The position seeks a tax professional for the Treaty Assistance and Interpretation Team (TAIT) within the office of the Treaty and Transfer Pricing Operations (TTPO), under the direction of the Director, Advance Pricing and Mutual Agreement, Large Business and International Division.
- Receives and reviews taxpayer requests for assistance in obtaining relief from double taxation including, forexample, requests for relief under treaty provisions concerning residency, limitations of benefits, artists,athletes and entertainers, withholding, and all issues other than those involving transfer pricing and relatedallocation of business profits provisions, to determine if such requests comply with procedural guidelines.
- Conducts independent research and analysis of tax, accounting, treaty, and economic issues and coordinateswith IRS subject-matter experts, when necessary.
- Prepares positions and other memoranda for the U.S. Competent Authority, recommending a course of actionbased on analysis of the facts of the case, applicable tax law and treaty provisions, and the position of theforeign country.
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