Managing Complex IRS Audits of Large- and Medium-Sized Business Taxpayers
Navigating Examination Processes, IRS Summonses, Section 982 Foreign-Based Documentation, "Unagreed" Audits
Recording of a 110-minute CPE/CLE webinar with Q&A
This webinar will provide guidance and best practices for responding to IRS audits of large- and medium-sized business taxpayers, including detailing IRS examination techniques, how to respond to and defend summons, navigating IRC Section 982 foreign-based documentation, and handling “unagreed” audits (appeals and fast-track settlement agreements).
Outline
I. Overview of IRS Request for Information Processes
II. “Unagreed Audits” and IRS changes to taxpayer’s account
III. Taxpayer’s appeal rights and options
IV. Litigation options and strategies
Benefits
The panel will address these and other key issues:
- What are the IRS’ powers in the various types of information requests at different stages of the audit/examination process?
- What defenses may a taxpayer assert in response to an IRS summons?
- What are the processes for the IRS to request foreign-based documentation?
- What are the taxpayer’s options to challenge an IRS audit finding?
Faculty
Jamie E. Brown
Atty
Kilpatrick Townsend & Stockton
Mr. Brown advises on tax-related matters, with a focus on federal tax controversies and litigation. Prior to... | Read More
Mr. Brown advises on tax-related matters, with a focus on federal tax controversies and litigation. Prior to joining his current firm, he was a trial attorney with the Tax Division of the U.S. Department of Justice, and before that, as an attorney with a law firm, he focused on the tax issues of large corporations.
CloseAntoinette L. Ellison
Atty
Kilpatrick Townsend & Stockton
Ms. Ellison focuses her practice on the resolution of federal and state tax-controversies on behalf of individual and... | Read More
Ms. Ellison focuses her practice on the resolution of federal and state tax-controversies on behalf of individual and corporate taxpayers and litigation. Prior to joining her current firm,she successfully represented public corporations, financial institutions, and accounting firms in securities cases and regulatory investigations.
CloseSusan S. Hu
Atty
Kilpatrick Townsend & Stockton
Ms. Hu focuses her practice on tax controversy and litigation with a particular focus on corporate income tax,... | Read More
Ms. Hu focuses her practice on tax controversy and litigation with a particular focus on corporate income tax, estate tax, and employment tax as well as other tax-related matters such as foreign bank account reporting and employee benefits. She began her career as an attorney with the I.R.S. Office of Chief Counsel where she provided formal and informal advice to I.R.S. Appeals, Collection and Examination.
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