tax audits & appeals david robison tom wilson
Post on 04-Jan-2016
42 Views
Preview:
DESCRIPTION
TRANSCRIPT
Tax Audits & Appeals
David Robison
Tom Wilson
2
Audit Strategy
> Transparency- Educating the audit team- Information sharing between taxing jurisdictions- Benefits of transparency- Impact of Schedule M-3 or other disclosures- the Silicon Valley Compliance Initiative Project
> Compliant v. Non-Compliant Taxpayers- How does the IRS make these determinations?- Consequences of being classified as compliant or non-
compliant- Transitioning towards compliance
3
Tax Accrual Workpapers> Revised Policy Announced in 2002
- Since the Arthur Young case, the IRS only requested tax accrual workpapers under unusual circumstances
> IRS said in Announcement 2002-63 that it will continue its policy of restraint and will not request accrual workpapers as a standard examination technique
> Exceptions:- Listed transactions- Financial irregularities & restatements
> The recent litigation involving Textron is an example of the government’s determination to pursue this issue
4
Penalties
> Routine part of examinations; no longer a “bargaining chip”- Penalty issues considered independently
> Approved by Director of Field Operations, not agent
> New “standard form” IDR regarding tax opinions
> “Penalty Proofing”
5
Issue Resolution> Private Letter Rulings> Tech Advice> Pre-filing Agreements (PFAs) & Advance Pricing Agreements
(APAs)> Compliance Assurance Program (CAP)> Limited Issue Focused Examinations (LIFE)> Appeals
- Early Referral- Fast Track- Mediation
> Coordination with foreign tax authorities
*See Handout entitled “Recently Developed IRS Audit and Dispute Resolution Techniques” by Pamela F. Olson and David B. Robison.
top related