IRS Alternative Dispute Resolution Strategies
Evaluating and Leveraging ADR Options in Tax Disputes
Recording of a 110-minute CPE/CLE webinar with Q&A
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.
Outline
- Evolutions of IRS offerings of ADR on tax matters
- Pre-filing ADR options
- Pre-filing determinations of non-controversial items
- Advance pricing agreements on transfer pricing structures
- Advance valuation of art works
- ADR options before the audit closes
- Early referral of disputed issues to Appeals
- Fast-track settlement for large and mid-sized taxpayers
- Fast-track mediation for small businesses and self-employed
- ADR options after the audit is finished
- Post-appeals mediation
- For issues unresolved after appeals or when closing agreement talks fail
- Binding arbitration of issues already before Appeals
- Post-appeals mediation
- Evaluating ADR vs. Appeals Division
- Is Office of Appeals sufficiently independent?
- Pros and cons of ADR
- Forging a plan that includes ADR
Benefits
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.
Faculty
David Blair
Member
Miller & Chevalier
His practice concentrates on federal tax litigation and alternative dispute resolution, and he speaks frequently about... | Read More
His practice concentrates on federal tax litigation and alternative dispute resolution, and he speaks frequently about ADR. He works extensively on matters before the IRS Examination and Appeals divisions, National Office, Advance Pricing Agreement Program and U.S. Competent Authority.
CloseTodd Welty
Partner
SNR Denton
He leads the firm's tax controversy group and represents a broad range of corporate, closely held business and... | Read More
He leads the firm's tax controversy group and represents a broad range of corporate, closely held business and individual tax clients. He has extensive experience at all levels of IRS tax disputes, including mediation, administrative appeals and court actions.
CloseElizabeth Erickson
Partner
McDermott Will & Emery
Her practice concentrates on tax controversies and tax litigation before the IRS Examinations Division and National... | Read More
Her practice concentrates on tax controversies and tax litigation before the IRS Examinations Division and National Office, U.S. Tax Court and U.S. district courts. She has spoken and written on the use of ADR in federal tax controversies.
CloseDavid Click
Tax Director
McGladrey
His career before coming to McGladrey also includes stints with the IRS Office of Associate Chief Counsel (Technical),... | Read More
His career before coming to McGladrey also includes stints with the IRS Office of Associate Chief Counsel (Technical), and working on federal tax matters for 12 years at KPMG and PricewaterhouseCoopers.
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