1 / 5

Tax Audits & Appeals David Robison Tom Wilson

Tax Audits & Appeals David Robison Tom Wilson. 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

holden
Download Presentation

Tax Audits & Appeals David Robison Tom Wilson

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. 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.

More Related