Legal Divisions

Divisions

As an attorney with the Office of Chief Counsel you will work for one of 13 major Counsel organizations, based on your particular interest, qualifications, and the staffing needs of the Office. Whether you are in a field office or National Office position, you will receive substantial training and responsibility.

Programs within the Office of Chief Counsel

NATIONAL OFFICE IN WASHINGTON, DC

  • Corporate (CORP)
    The Associate Chief Counsel, Corporate, employs approximately 60 attorneys who work in the National Office in Washington, DC. These attorneys provide published guidance, field support, and taxpayer advice on tax matters involving corporate organizations, reorganizations, liquidations, spin-offs, transfers to controlled corporations, distributions to shareholders, debt vs. equity determinations, bankruptcies, and consolidated return issues affecting groups of affiliated corporations among other matters.

  • Financial Institutions & Products (FIP)
    The Associate Chief Counsel, Financial Institutions and Products, employs approximately 50 attorneys who work in the National Office in Washington, DC and provide published guidance, field support, and taxpayer advice on tax matters involving financial institutions and financial products. These financial institutions include banks, thrift institutions, insurance companies, regulated investment companies, and real estate investment trusts. Financial products covered by the Division consist of asset securitization arrangements, life insurance contracts, annuities, options, forward contracts, futures contracts, notional principal contracts, original issue discount obligations, hybrid instruments, hedging arrangements, and other types of innovative financial arrangements and transactions.

  • Income Tax & Accounting (ITA)
    The Associate Chief Counsel, Income Tax and Accounting, employs approximately 100 attorneys and accountants who work in the National Office in Washington, DC. The Division drafts published guidance, provides advice to field offices on technical issues and litigation matters, and issues rulings and information letters to taxpayers. The Division has jurisdiction over several major tax areas: recognition and timing of income; deductions and credits for individuals and corporations; depreciation and costing; sales and exchanges; capital gains and losses; accounting methods and periods; installment sales; long-term contracts; inventories; and alternative minimum tax.

  • International (INTL)
    The Associate Chief Counsel, International, employs approximately 90 attorneys and program analysts (the latter being economists in the Advanced Pricing Agreement (APA) Program), the majority of whom work in the National Office in Washington, DC. Others work on the west coast at a branch office of International’s APA program. These attorneys provide legal advisory services on all international and foreign tax matters, including all matters relating to the activities of non-U.S. persons or entities within the United States and the activities of U.S. or U.S.-related persons or entities outside the United States. These legal advisory services support uniform interpretation, application, enforcement, and litigation of the tax laws related to all international provisions of the United States revenue laws, all bilateral and multilateral tax treaties and agreements to which the United States is a party, and all foreign revenue laws relating to tax matters in the United States.

  • Passthroughs & Special Industries (PSI)
    The Associate Chief Counsel, Passthroughs & Special Industries, employs approximately 80 attorneys who work in the National Office in Washington, DC. This office provides published guidance, field support, and taxpayer advice regarding income taxation of passthrough entities such as partnerships (including limited liability corporations), S corporations, trusts and estates; natural resources and energy related credits and incentives; cooperative housing corporations and homeowner associations; farmers' and other cooperatives; business tax credits, including the low-income housing credit, and the research credit; estate, gift, and generation skipping transfer taxes; certain excise taxes; and the domestic production deduction.

  • Procedure & Administration (P&A)
    The Associate Chief Counsel, Procedure & Administration, located in the National Office in Washington, DC, is comprised of approximately 100 attorneys. P&A attorneys handle a broad range of issues and assignments that are fundamental to efficient tax administration, advising the Chief Counsel and the IRS in all facets of judicial and tax practice. P&A attorneys deal with legal issues arising in IRS initiatives and enforcement activities, and often address these issues in the context of a system that is transitioning from reliance on paper documents and returns to one that is primarily based on electronic documents and returns. P&A attorneys handle published guidance, advice, and litigation on all matters related to reporting and paying taxes; assessing and collecting taxes (including interest and penalties); abating, crediting, or refunding over assessments or overpayments of tax; filing information returns; bankruptcy; summonses and information gathering; federal tax liens and levies; damage claims; attorney fees; disclosure, privacy, and Freedom of Information Act issues; and judicial practice and judicial doctrines. Additionally, P&A attorneys have the opportunity to argue motions before the Tax Court.

  • Special Counsel to the National Taxpayer Advocate (CNTA)
    The Office of the Special Counsel to the National Taxpayer Advocate, employs several attorneys who provide legal advice and support to the National Taxpayer Advocate. The Counsel to the NTA is responsible for coordinating all legal and advisory services to the National Taxpayer Advocate and the headquarters component of the Taxpayer Advocate Service. In addition, the Counsel to the NTA serves as a liaison between the NTA and the Chief Counsel, informing the Chief Counsel of emerging NTA issues and advising the NTA of Chief Counsel initiatives, recent court opinions, and published guidance which may impact the taxpayer advocate program.

  • Wage & Investment (W&I)
    The Office of the Division Counsel, Wage and Investment, is responsible for providing legal advice and support on matters that involve taxpayers who generally have income reported only on Forms W-2 and 1099. The Division Counsel is located in Washington, DC and provides advice and support for the W&I Division Commissioner, his headquarters’ staff and the W&I Senior Leadership Team. The Division Counsel works closely with W&I in advancing the Division’s programs and initiatives, reviewing policies, formulating strategies, and furthering the Division’s goal of providing efficient and effective taxpayer service. The Division Counsel coordinates the delivery of a myriad of legal services for W&I with other Chief Counsel functions, including the Associate Chief Counsel, General Legal Services; Associate Chief Counsel, Procedure & Administration; and Division Counsel, Small Business/Self Employed which has primary responsibility for providing legal services to the W&I field organization.

NATIONAL & FIELD OFFICES

  • Criminal Tax (CT)
    The Division Counsel/Associate Chief Counsel, Criminal Tax, employs approximately 70 attorneys in over 30 offices across the country. Criminal Tax attorneys are responsible for providing legal advice and assistance to criminal investigation in all areas of the Criminal Tax function, including tax, currency, and money laundering crimes and criminal procedure. They also provide legal counsel on investigative matters such as administrative and grand jury investigations, undercover operations, electronic surveillance, search warrants and forfeitures, the referral of cases to the Department of Justice for grand jury investigation, criminal prosecution, and the commencement of forfeitures. Criminal Tax attorneys also coordinate with other offices within the IRS and the Office of Chief Counsel on all matters involving criminal tax.

  • General Legal Services (GLS)
    The Office of Associate Chief Counsel, General Legal Services, employs approximately 70 attorneys, and has both field and National Office components. GLS litigates cases as the representative of the IRS and the Office of Chief Counsel in various fora with respect to non-tax, administrative law issues involving personnel, discrimination, labor management relations, Office of Professional Responsibility, and government contracts as well as handling litigation with the Department of Justice. The Associate Chief Counsel is the Deputy Ethics Official under the Ethics in Government Act with regard to constitutional and tort issues. GLS attorneys also perform legal research and provide advice related to conflict of interest statutes, ethical standards, and Departmental rules of conduct. GLS also has a robust practice in the area of advisory opinions on legal matters, including procurement, information technology management, appropriations, grant law, and intellectual property law.

  • Tax Exempt & Government Entities (TEGE)
    The Division Counsel/Associate Chief Counsel, Tax Exempt & Government Entities, combines strategic, technical, and litigation functions into a single integrated office. The approximately 130 attorneys provide the full range of legal services from guidance through litigation in the areas of qualified plans, health, welfare, and other employee benefits, executive compensation and fringe benefits, exempt organizations, and employment taxes. In addition they handle litigation in the tax exempt bond area and provide significant legal support for issues involving governmental agencies and Indian Tribal Governments. Over 90 of our attorneys are located in the National Office in Washington, DC where they combine legal advisory services with the development of published guidance, advice on legislation, and support to the Department of Justice and field attorneys on litigation. The remainder of our attorneys are located in several field offices around the country, including Chicago, Dallas, Long Island, Baltimore, Denver, and Los Angeles/Thousand Oaks. These attorneys provide a full range of legal advice and represent the IRS in litigation in the U.S. Tax Court.

COUNSEL FIELD FUNCTIONS

  • Large & Mid-Size Business (LB&I)
    The Large & Mid-Size Business Division Counsel provides legal services to the IRS LB&I Division, an industry focused organization with an emphasis on global tax administration for corporations and partnerships with assets greater than $10 million. The Division Counsel employs over 290 attorneys located in 39 cities nationwide. Headquartered in Washington, DC, the Division has five Area Counsels located in Pennsylvania, New York, Illinois, Texas, and California. Each Area Counsel is responsible for legal work within a defined geographic area and for developing specialized knowledge of one of the industries served nationally by the IRS including: financial services; heavy manufacturing and transportation; retail, food, pharmaceuticals, and health care; natural resources and construction; and communications, technology, and media. The LB&I attorneys provide a full range of legal services on all issues, including advising LB&I compliance agents, handling litigation in the U.S. Tax Court, and assisting the Department of Justice in the handling of refund cases in the U.S. District Courts.

  • Small Business/Self Employed (SB/SE)
    Small Business/Self Employed is the largest Chief Counsel Division, with 450 attorneys and 100 paralegals assigned to 49 field offices. These attorneys work directly with IRS field agents providing legal advice on tax cases involving individuals and small businesses, and on all cases involving collection and bankruptcy issues. When these cases go to trial, SB/SE attorneys are the IRS litigators, with direct responsibility for identifying the desired legal theories, developing the trial strategies, and representing the IRS in court.

    SB/SE attorneys typically spend most of their time handling Tax Court and bankruptcy cases. Over 90 percent of the 30,000 Tax Court cases filed each year are assigned to SB/SE attorneys. In most field offices, bankruptcy cases are assigned to attorneys who are designated as Special Assistant U.S. Attorneys. Attorneys may also be assigned to assist the Department of Justice in the handling of collection, refund, and other cases in the U.S. District Courts. Through client support and litigation, SB/SE attorneys have an opportunity to further their knowledge of tax law and to develop expertise on a wide variety of complex technical, procedural, and tax issues.

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