CD of a Teleconference with Q&A Session
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U.S. companies seeking to avoid a prolonged IRS audit can leverage two government advance-review opportunities: the pre-filing agreement, or PFA, program and the compliance assurance program, or CAP.
Under PFA, taxpayers can ask the IRS to examine and resolve tax positions that it's likely to challenge before companies file their returns. PFA provides protection against future IRS penalties, and PFA issues may be resolved for the next four years.
Under the CAP, taxpayers work with the IRS large and mid-sized business division to resolve the proper tax treatment of controversial transactions throughout the year – in effect, a real-time audit.
If companies approach these programs realistically, there are substantial potential benefits. Companies get a clear read on their federal income tax liability for a given year within months, rather than years. Overall compliance costs and fees should be lower.
Listen as our expert panel of tax advisors discusses all aspects of the PFA and CAP programs to help you decide whether your company should enroll.
The panel discussed these and other key questions:
- The potential downside to inviting the IRS an advance insider’s view of your company’s tax compliance. How protected are you, really?
- What kinds of experiences have participants in these programs reported.
- Evaluating which tax positions and transactions should, from your company’s perspective, be part of one of these programs.
- How to write a beneficial closing agreement with IRS input.
Our panel includes:
Kevin Johnson is a shareholder member in the Conshohocken, Pa.-based Chamberlain Hrdlicka White Williams & Martin law firm, specializing in federal tax controversies and domestic and international tax planning. He represents large corporate clients before U.S. Tax Court, Court of Federal Claims and 10th Circuit Court of Appeals on a broad range of tax planning issues. Previously, Kevin was a member with the Miller & Chevalier law firm and an attorney with the Dechert law firm, both based in Philadephia, and an IRS agent.
David Bowen is a tax partner with Mayer Brown Rowe & Maw in Washington, where his practice specializes in federal tax controversies and transfer pricing. David previously served as special counsel to the associate chief counsel international of the IRS, where he led the issue-identification stages of revisions to the Sect. 482 cost-sharing regulations in 1995, and was principal drafter for that project.
Steve Whiteaker is manager of the tax shelter analysis program at the IRS and former manager of the PFA program.
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TELECONFERENCE CD
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