Senior Level Counsel (TEGEDC)

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The Senior Level Counsel serves as the lead technical expert to the Division Counsel and Deputy Division Counsel of the Tax Exempt and Government Entities Division (TEGEDC) for matters under the jurisdiction of TEGEDC, including employee benefit programs (including qualified retirement plans, deferred compensation arrangements, and health and welfare programs), executive compensation, exempt organizations, federal, state, local and Indian tribal governments, tax-exempt bonds, and employment tax. The Senior Level Counsel leads the effort to assist clients in identifying emerging issues and developing compliance strategies. The Senior Level Counsel assists senior executives in the formulation of policies and programs for the operation of the Office of Chief Counsel and performs special assignments of the highest complexity and impact on a case or project. Major duties of the Senior Level Counsel include, but are not limited to the following: Acts as a legal and technical expert to Counsel executives on the most difficult, important, and complex professional legal matters arising in the administration of the internal revenue laws. Serves as a chief legal advisor to the Division Counsel and Deputy Division Counsel on sensitive and controversial litigation strategies, transactions, and other technical TEGEDC issues and matters such as those involving political campaign activities, churches, or high-profile organizations or entities. Analyzes legal and policy matters affecting the IRS Client (i.e., TE/GE, Small Business/ Self-Employed (SB/SE) Employment Tax, and Large Business & International (LB&I) Compensation and Benefits) by interpreting legal principles in a practical manner so that these clients can incorporate those principles into their business practices; harmonizes legal and policy issues; develops new or alternative positions to meet changing business needs; and provides seasoned judgment and advice. Serves as a technical expert and liaison for TEGEDC and the Office of Chief Counsel on the most significant litigation and litigation-related matters with the IRS, the Department of Justice (DOJ), and the Department of the Treasury. Coordinates and collaborates with other Division and Associate offices to maintain a consistent litigation approach within and between Divisions, to support the Division's efforts to sustain continued success of all aspects of TEGEDC's litigation program. Provides legal advice and guidance to the IRS on abusive transaction matters involving TEGEDC issues; assists with formulation of compliance efforts, settlement initiatives, and litigation strategies; provides technical expertise to IRS executives, technical advisors, and program managers; and oversees promoter and preparer investigations and suits. Directly supports TEGEDC clients and serves as the agency expert and technical lead across Counsel on all matters relating to promoter and preparer investigations. Advises on a broad array of activities designed to fulfill Counsel's responsibilities to prepare, review, and assist in the preparation of proposed legislation involving matters under the jurisdiction of TEGEDC. Manages complex and significant special projects for TEGEDC, including selecting and reviewing proposals, monitoring work group needs and progress, and facilitating the movement of recommendations regarding these matters through the decision-making process. Represents Counsel at top level IRS and Treasury meetings and conferences and in meetings with executives from other agencies where policy is developed and determined. Such representations are for the purposes of furthering, setting forth, and explaining the position of Counsel, the IRS, and Treasury as they relate to matters under the jurisdiction of TEGEDC. Performs exhaustive and detailed research on complicated legal problems and prepares recommendations as to the position to be taken by Counsel. Makes such recommendations without review and as appropriate except for cases where the Senior Level Counsel assesses a higher-level review is required or as otherwise specifically directed. Performs other duties as assigned and/or delegated by the Chief Counsel, Deputy Chief Counsels or Division Counsel.