determines are appropriately qualified to handle the most complex tax cases. (d) Structure (1) In general The program shall be staffed by not fewer than 30 fellows at the discretion of the Commissioner based on needs of the Internal Revenue Service and the availability of qualified candidates. (2) Term of service (A) In general Each fellow shall be hired for a 2-, 3-, or 4-year term of service. (B) Extensions (i) In general A fellow may apply for, and the Commissioner may grant, a 1-year extension of the fellowship. (ii) No limit on number of extensions There shall be no limit on the number of extensions under clause (i). (3) Fellowship vacancies The Commissioner, after consultation with the Chief Counsel, shall fill vacant fellowships— (A) in such a manner as to ensure that the program is staffed with no fewer than 15 fellows, and (B) as soon as practicable after the vacancy arises. (4) Hiring authority The Commissioner shall have authority to permanently hire a fellow at the end of the term of service for such fellow. (e) Task force Not later than the date on which the first fellowship is awarded under this section, the Commissioner shall establish a task force within the Internal Revenue Service and the office of the Chief Counsel in both national and regional office placements that includes the fellows hired pursuant to subsection (d), the purpose of which is to— (1) perform audit case selection, (2) educate Internal Revenue Service employees on emerging issues, (3) audit selected taxpayers, (4) address offshore tax evasion and issues implicating the Foreign Account Tax Compliance Act, and (5) identify, mentor, and train junior employees from the Internal Revenue Service with respect to audits. (f) Composition The task force established under subsection (e) may be composed of both— (1) fellows, and (2) permanent employees of the Internal Revenue Service. (g) Pay of fellows (1) In general The Secretary of the Treasury (or the Secretary’s delegate) shall determine, subject to the provisions of this subsection,