IRS Alternative Dispute Resolution Strategies

Evaluating and Leveraging ADR Options in Tax Disputes

Recording of a 110-minute CPE/CLE webinar with Q&A

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Conducted on Thursday, March 24, 2011

Recorded event now available

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Course Materials

This teleconference will prepare tax executives and advisors to utilize the IRS alternative dispute resolution (ADR) programs and to evaluate its potential to leverage a successful resolution of a disputed federal tax item from the taxpayer's perspective.


Many companies find aspects of the IRS' alternative dispute resolution (ADR) procedures for tax outdated and untimely, but both the Service and taxpayers have a strong interest in resolving a disputed issue before it gets to the Appeals Division or litigation.

Taxpayers can leverage several ADR options before a return is filed (pre-filing determinations for non-controversial items), during the audit (early referrals of disputed items and fast-track settlements), and after the audit (post-appeals mediation and binding arbitration of issues before Appeals).

However, taxpayers must first grasp both the formal program rules and practical realities of each ADR procedure, as well as the pros and cons, before agreeing to participate. In that regard, an evaluation of IRS options by veteran tax advisors can position you to make sound decisions about ADR.

Listen as our experienced panel provides a thorough briefing of the IRS ADR process for corporate tax, grounded in practical experiences with the Service.



  1. Evolutions of IRS offerings of ADR on tax matters
  2. Pre-filing ADR options
    1. Pre-filing determinations of non-controversial items
    2. Advance pricing agreements on transfer pricing structures
    3. Advance valuation of art works
  3. ADR options before the audit closes
    1. Early referral of disputed issues to Appeals
    2. Fast-track settlement for large and mid-sized taxpayers
    3. Fast-track mediation for small businesses and self-employed
  4. ADR options after the audit is finished
    1. Post-appeals mediation
      1. For issues unresolved after appeals or when closing agreement talks fail
    2. Binding arbitration of issues already before Appeals
  5. Evaluating ADR vs. Appeals Division
    1. Is Office of Appeals sufficiently independent?
    2. Pros and cons of ADR
    3. Forging a plan that includes ADR


The panel will analyze these and other substantive aspects of ADR:

  • Material terms of all ADR procedures available to corporate taxpayers before filing, during an audit, and before or during a formal appeal.
  • Evaluating the relative benefits and disadvantages of ADR vs. going through the Appeals Division.
  • Crafting an advance strategy for your company to use ADR.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


David Blair
David Blair

Miller & Chevalier

His practice concentrates on federal tax litigation and alternative dispute resolution, and he speaks frequently about...  |  Read More

Todd Welty
Todd Welty

SNR Denton

He leads the firm's tax controversy group and represents a broad range of corporate, closely held business and...  |  Read More

Elizabeth Erickson
Elizabeth Erickson

McDermott Will & Emery

Her practice concentrates on tax controversies and tax litigation before the IRS Examinations Division and National...  |  Read More

David Click
David Click
Tax Director

His career before coming to McGladrey also includes stints with the IRS Office of Associate Chief Counsel (Technical),...  |  Read More

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