The Chief Counsel for the Internal Revenue Service (IRS) provides advice to the IRS Commissioner on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue laws, represents the IRS in litigation, and provides all other legal support needed by the IRS to carry out its mission of serving America’s taxpayers. In carrying out these responsibilities, Counsel must interpret the law with complete impartiality so that the American public will have confidence that the tax law is being applied with integrity and fairness.

The Office of Chief Counsel (Office) prepares legislative proposals, regulations, revenue rulings and procedures, actions on decisions, and other items of public guidance and legal advice. The Office coordinates these matters with other components of the Service, the Treasury Department, other government agencies, and international organizations.

The Office of Chief Counsel coordinates the IRS’s position in litigation with the IRS and the Department of Justice in order to ensure the Operating Divisions are taking consistent and appropriate technical positions in litigation. The Office prepares recommendations concerning defense, settlement, appeal, or certiorari; and coordinates other matters with the Department of Justice as required.

The Office of Chief Counsel reviews and coordinates pleadings, motions, briefs, settlement documents, notices of appeal, and any other material prepared in connection with United States Tax Court litigation. The Office processes petitions and complaints, briefs, actions on decision, and other matters.

The Office of Chief Counsel develops policy, procedure, directives, Chief Counsel Notices, Litigation Guideline Memorandums, and Chief Counsel Directives Manual provisions to provide uniform application of law and regulation. The Office provides support and guidance in connection with the development of Internal Revenue Manual provisions.

The Office of Chief Counsel issues Technical advice, and other legal advice responding to questions raised by IRS personnel. The Office reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

The Office of Chief Counsel issues letter rulings and general technical information letters in response to requests from taxpayers.

The Office of Chief Counsel also provides guidance on legal matters involving the IRS in the areas of claims, labor and personnel law; ethics and general government law; and public contracts and technology law.

The Deputy Chief Counsel (Technical) maintains jurisdiction over legal issues arising in published guidance, letter rulings, technical advice, and other processes. The Deputy Chief Counsel (Technical) participates in the interpretation and development of internal revenue laws.

The Deputy Chief Counsel (Technical) supervises:

The Deputy Chief Counsel (Operations) maintains jurisdiction over issues arising in litigation nationwide and has primary responsibility for matters involving management of the Office of Chief Counsel. The Deputy Chief Counsel (Operations) participates in the formulation of tax litigation policy.

The Deputy Chief Counsel (Operations) supervises:

The Executive Counsel to the Chief Counsel, Special Counsels and other senior advisors serve on the immediate staff of the Chief Counsel to provide advice and guidance regarding the formulation of policy; the management of the legal programs of the Office; the preparation and review of proposed legislation, implementation of complex legislation; or technical and legal issues of interest to the Chief Counsel or the IRS.

Associate Chief Counsel (Corporate) (CC:CORP) reports to the Deputy Chief Counsel (Technical). The office of the Associate Chief Counsel (Corporate) is located in Washington, D.C., consisting of:

The Associate Chief Counsel (Corporate) is responsible for tax matters involving:

The office of the Associate Chief Counsel (Corporate) furnishes information, advice, and assistance in the development and drafting of internal revenue legislation, initiates legislative recommendations and in coordination with Legislative Affairs, advises the Associate General Counsel (Legislation, Litigation, and Regulation) regarding the views of the Office of Chief Counsel on proposed or pending legislation.

The office of the Associate Chief Counsel (Corporate) drafts proposed and final regulations, reviews public comments, conducts public hearings and participates in review of proposed and final regulations within the IRS and with the Department of Treasury.

The office of the Associate Chief Counsel (Corporate) drafts revenue rulings, revenue procedures, actions on decision, announcements, notices, news releases, and statements of the Office of Chief Counsel and participates in review of these documents within the Service and with the Department of Treasury.

The office of the Associate Chief Counsel (Corporate) issues private letter rulings to provide guidance for taxpayers and their advisers regarding the federal tax consequences of corporate transactions.

The office of the Associate Chief Counsel (Corporate) issues technical advice memoranda and other legal advice to IRS personnel.

The Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) (CC:EEE) reports to the Deputy Chief Counsel (Technical). The office of Associate Chief Counsel (EEE), located in Washington, D.C. consists of:

The office of Associate Chief Counsel (EEE) is responsible for issues pertaining to the uniform interpretation and application of federal tax laws involving:

The office of the Associate Chief Counsel (EEE) provides legal and technical advice with respect to legislation: issues, regulations, and other guidance, letter rulings, and advisory opinions; and provides litigation support within its jurisdiction.

The Associate Chief Counsel (Finance & Management) (CC:FM) reports to the Deputy Chief Counsel (Operations). The office of the Associate Chief Counsel (F&M) consists of a number of divisions and technical and administrative staff in Washington, D.C., and three areas in the field.

The office of the Associate Chief Counsel (F&M) supports the administrative, financial and managerial programs of the Office of Chief Counsel. The office of the Associate Chief Counsel (F&M) performs all Counsel-wide finance and management activities. The office’s major functional areas include:

The office of the Associate Chief Counsel (F&M) manages Counsel’s business systems and strategic planning processes, system coordination, and organizational studies and analyses.

The office of the Associate Chief Counsel (F&M) directs the management of the Chief Counsel Library, a highly specialized tax law library system, which supports Chief Counsel and IRS staff in all substantive areas pertaining to tax law.

The Associate Chief Counsel (Financial Institutions & Products) (CC:FIP) reports to the Deputy Chief Counsel (Technical). The office of the Associate Chief Counsel (FIP), located in Washington, D.C., consists of:

The office of the Associate Chief Counsel (FIP) provides legal advice, litigation services, and litigation support on tax matters involving financial institutions and the taxation of financial products including:

The Office of the Associate Chief Counsel (FIP) prepares legislative proposals, regulations, revenue rulings and procedures, actions on decisions, and other items of public guidance and legal advice and coordinates these matters with other components of the IRS, the Treasury Department, and other government agencies.

The office of the Associate Chief Counsel (FIP) issues technical advice or other legal advice responding to questions raised by IRS personnel. The Office reviews booklets, training materials, Audit Technique Guides, Coordinated Issue Papers, Appeals Settlement Guidelines, forms, publications and instructions to ensure technical accuracy, and upon request, assists in their preparation.

The office of the Associate Chief Counsel (FIP) issues letter rulings and general technical information letters in response to requests from taxpayers.

The Associate Chief Counsel (General Legal Services) (CC:GLS) reports to the Deputy Chief Counsel (Operations). The office of the Associate Chief Counsel (GLS) consists of three technical program offices in Washington, D.C. and six Area Counsel offices located in Atlanta, Chicago, Dallas, Manhattan, San Francisco, and Washington, D.C.

The office of the Associate Chief Counsel (GLS) represents the IRS and the Office of Chief Counsel in all proceedings not directly related to tax issues, with the exception of Freedom of Information Act (FOIA) and Privacy Act matters, including:

The office of the Associate Chief Counsel (GLS) reviews and coordinates, as appropriate, pleadings, briefs, settlements, documents, notices of appeal and other materials prepared in connection with cases before a court, including the U.S. Tax Court, related to conflict of interest or ethical matters.

The Associate Chief Counsel (GLS) also has the delegated authority as the Deputy Ethics Official (DEO).

The Associate Chief Counsel (Income Tax & Accounting) (CC:ITA) reports to the Deputy Chief Counsel (Technical). The office of Associate Chief Counsel (ITA), located in Washington, D.C., consists of:

The office of the Associate Chief Counsel (ITA) provides legal advice, litigation services, and litigation support on tax matters involving:

The office of the Associate Chief Counsel (ITA) performs the functions of the Office of Chief Counsel described in IRM 1.1.6.1(1)-(7).

The Associate Chief Counsel (International) (CC:INTL) reports to the Deputy Chief Counsel (Technical). The office of Associate Chief Counsel (International) consists of seven technical branches, and administrative staff. The office of the Associate Chief Counsel (International) is located in Washington, D.C.

The office of the Associate Chief Counsel (International) provides legal advice to support the uniform interpretation, application, enforcement, and litigation of all international and foreign tax matters:

The office of the Associate Chief Counsel (International) formulates and coordinates goals and strategies for the effective and comprehensive strategic management of international issues and assists the Treasury Department and other government agencies in tax treaty negotiations and in negotiations with respect to other international agreements.

The office of the Associate Chief Counsel (International) provides legal advice to LB&I and SBSE in developing and implementing campaigns involving international tax matters.

The office of the Associate Chief Counsel (International) provides legal advice and assistance to the U. S. Competent Authority, Treaty and Transfer Pricing Operations (TTPO), and Treaty Assistance and Interpretation Team (TAIT) on transfer pricing issues and matters of treaty interpretation and implementation, including both substantive legal issues as well as all procedural issues arising out of treaty-based processes, such as information exchange and cross-border information gathering and collection processes.

The Associate Chief Counsel (Passthroughs & Special Industries) (CC:PSI) reports to the Deputy Chief Counsel (Technical). The office of Associate Chief Counsel (PSI), located in Washington D.C., consists of:

The office of the Associate Chief Counsel (PSI) provides legal guidance, litigation services and litigation support for tax matters involving:

The Associate Chief Counsel (Procedure & Administration) (CC:PA) reports to the Deputy Chief Counsel (Operations). The office of the Associate Chief Counsel (P&A), located in Washington, D.C., consists of:

The office of the Associate Chief Counsel (P&A) provides legal advice, litigation services, and litigation support on all facets of judicial and federal tax procedure and administrative practice including matters relating to:

The office of Associate Chief Counsel (P&A) approves actions to be taken with respect to U.S. Tax Court subpoenas and disclosure of information in Tax Court litigation.

The office of Associate Chief Counsel (P&A) serves as the Commissioner’s delegate for assertion of claims of executive privilege involving internal or interagency records or information that are predecisional and deliberative in matters before the U.S. Tax Court, U.S. Court of Federal Claims and other federal courts.

The Associate Chief Counsel (P&A) serves the Office of Chief Counsel as the designated Sanctions Officer for purposes of Executive Order 12988, Civil Justice Reform.

The Division Counsel/Associate Chief Counsel (Criminal Tax) (CC:CT) reports to the Deputy Chief Counsel (Operations). The Office of the Division Counsel/Associate Chief Counsel (CT) consists of technical, planning, and administrative staff in Washington, D.C., and six geographic areas in the field.

The Division Counsel/Associate Chief Counsel (CT) provides legal advice, plans, directs, and coordinates policies and programs with respect to substantive criminal matters, criminal procedure and investigative matters, including:

The Division Counsel/Associate Chief Counsel (CT) provides full time senior attorney(s) as instructors at the National Criminal Investigation Training Academy (NCITA) at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia.

The Division Counsel (Large Business and International) (CC:LB&I) reports to the Deputy Chief Counsel (Operations). The office of Division Counsel (LB&I) consists of:

The office of the Division Counsel (LB&I) is the principal legal advisor to the LB&I Division of the Internal Revenue Service, and a legal advisor to the IRS Independent Office of Appeals. The Division Counsel (LB&I) has primary responsibility for providing litigation services and legal advice on matters involving domestic and multinational corporations, subchapter S corporations, partnerships with substantial assets, and global high-wealth individuals.

The office of the Division Counsel (LB&I) handles the litigation of cases pending in the United States Tax Court, and prepares enforcement, defense, and settlement letters in summons enforcement and refund litigation cases. The Division Counsel (LB&I) makes recommendations of acquiescence and nonacquiescence in adverse decisions in litigation.

The Division Counsel/Associate Chief Counsel (National Taxpayer Advocate Program) (CC:NTA) provides legal advice and support directly to the National Taxpayer Advocate (NTA) and headquarters employees of the Office of the Taxpayer Advocate (commonly referred to as the Taxpayer Advocate Service (TAS)) to assist TAS in fulfilling its mission and responsibilities as set forth in the Internal Revenue Code (IRC). As CC:NTA does not have a field component, the Office of the Division Counsel (Small Business/Self-Employed) serves as legal advisor to TAS field offices.

CC:NTA is responsible for matters that:

The Division Counsel (Small Business/Self-Employed) (CC:SB) reports to the Deputy Chief Counsel (Operations). The office of Division Counsel (SB/SE) consists of technical, planning, and administrative staff in Lanham, Maryland, and nine areas in the field.

The Division Counsel (SB/SE) is the principal legal advisor to the Division Commissioner, SB/SE, and to the field components of the Wage & Investment Division, the Taxpayer Advocate Service, and the SB/SE function of the Independent Office of Appeals.

The office of the Division Counsel (SB/SE) provides legal advice, services and litigation on matters relating to:

The Division Counsel (Strategic Litigation) (CC:SL) reports to the Deputy Chief Counsel (Operations). The office of the Division Counsel (SL) is a national organization with employees in various field offices across the country and consists of:

The headquarters office of the Division Counsel (SL) consists of:

The field offices of the Division Counsel (SL) consist of:

The office of the Division Counsel (SL) is responsible for the most significant and complex litigation in the United States Tax Court, including cases considered "Significant" under the Chief Counsel Significant Case Coordination Program.

The office of the Division Counsel (SL) provides legal advice and services to the Internal Revenue Service on its most significant non-docketed cases.

The office of the Division Counsel (SL) makes civil suit referrals to the Department of Justice and assists the Department of Justice in handling civil litigation in other federal courts and state courts.

The Division Counsel (Tax Exempt and Government Entities) (CC:TEGEDC) reports to the Deputy Chief Counsel (Operations). The office of Division Counsel (TEGEDC) consists of management, technical, and administrative headquarters staff, and six areas in the field.

The Division Counsel (Tax Exempt and Government Entities) is the principal legal advisor to the Division Commissioner, TE/GE, and to the Division Commissioner, SB/SE, on employment tax issues.

The office of the Division Counsel (TEGEDC) provides legal advice, services and litigation on program matters, including tax issues, relating to:

Area Counsel offices are designed as groups of versatile specialized staff providing nationwide advisory and litigation services to the TE/GE Operating Divisions on employee benefits, exempt organizations, employment taxes, Indian Tribal Government and government entities issues. In addition, Area Counsel offices provide advisory and litigation services to the SB/SE Employment Tax Exam functions.

TEGEDC’s six Areas and the location of the Area Counsel:

The Division Counsel (Wage & Investment) (CC:WI) reports to the Deputy Chief Counsel (Operations). The office of Division Counsel (W&I) consists of Special Counsel and is located in Washington, D.C.

The Division Counsel (W&I) provides advice on the legal issues, regulations, and needs relevant to serving all taxpayers who generally have income reported only on Forms W-2 and 1099.

The Division Counsel works closely with and provides advice to the IRS W&I Division Commissioner, the W&I Senior Leadership team and the W&I headquarters’ staff. That work includes advancing the Division’s programs and initiatives, reviewing policies, formulating strategies, and furthering the Division’s goal of providing efficient and effective taxpayer service programs including the filing, correction, and payment of federal income taxes; fraud and identity theft detection during return processing; and assistance to taxpayers in person and others by phone.

The field staff of the Division Counsel (Small Business/Self Employed) provides legal services to the IRS W&I Division field organization.

The Field Management Matrix is an integrated management structure that balances geographic and functional needs at all levels but does not change the existing Divisional lines of authority or supervisory chains of command. The Field Management Matrix focuses on office-wide issues of teamwork, resource allocation, and skill development. The matrix structure requires the appointed managers to assume additional duties to support cross-Divisional coordination and communication.

Managing Counsel are appointed in each of the 48 posts of duty to address issues that have an office-wide impact, such as the following:

Area Teams interact with Managing Counsel, assume a leadership role that transcends existing Division management roles, ensure collaboration and cooperation across Divisions, maintain high levels of Service-wide client satisfaction, and foster an effective relationship with the National Treasury Employees Union (NTEU). The teams are comprised of appointed representatives from each business unit, one of which is selected as the Team Leader, within the following geographic areas: