Tier I Audit Issues: Current IRS Priorities, Policies and Procedures

Preparing for the Latest IRS Approach to Examination and Enforcement

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

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Conducted on Thursday, January 13, 2011

Recorded event now available

or call 1-800-926-7926

This teleconference will prepare U.S. corporate taxpayers and advisors for the procedural realities of IRS Tier I examinations based on recent audits, IRS staff involvement, and announced changes in Tier I issues.


Corporate taxpayers may be familiar with the material details of the IRS' Tier I audit issues: which activities get mandatory exams due to high risk of non-compliance, and which are currently on active or monitoring status. Are you equally familiar with practical realities of Tier I audits?

U.S. companies must anticipate the centralized administration of Tier I audits; how facts are gathered through information document requests, interviews and additional informal discovery; and more active participation of IRS Chief Counsel or technical staff.

Adjusting your audit planning and preparation to the practical conduct of a Tier I audit is even more essential than grasping the substantive audit priorities. A briefing from tax advisors who deal constantly with the Service can help you refine your federal audit strategy.

Listen as our panel of veteran tax advisors analyzes the realities of the IRS' Tier I audit approach, the good and bad for corporate taxpayers, and how you might adjust in anticipation.



  1. Background of Tier I audit designation
    1. What it means for an issue to be “Tier I”
      1. Active and monitoring-status issues
    2. Recent IRS changes to Tier I policy
      1. E.g. withholding, transfer pricing, hybrid structures
  2. Lessons learned from recent IRS audits involving Tier I issues
    1. Issues drawing considerable attention
    2. Processes to develop facts with IDRs, informal discovery
    3. Level of interviewing of taxpayer personnel
    4. Involvement of chief counsel and technical staff
    5. Level of centralized control
  3. Recommendations to prepare more effectively for Tier I audits


The panel will address these and other relevant subjects:

  • Current Tier I topics of most interest to IRS agents, based on recent audit experiences.
  • The impact of increasingly centralized control of Tier I audits.
  • Approaches IRS examiners are using to determine and gather relevant facts.
  • Whether involvement of certain IRS staff is increasing transparency.
  • How the taxpayer can influence and improve audit preparation and conduct.


George Hani
George Hani

Miller & Chevalier

He is Vice Chairman of the firm's Tax Department and specializes in administrative appeals of federal tax disputes. He...  |  Read More

Jean Pawlow
Jean Pawlow

McDermott Will & Emery

She is a member of the firm's U.S. and International Tax Practice Group and chairwoman of its Federal Tax...  |  Read More

Matthew Lerner
Matthew Lerner

Steptoe & Johnson

He is attached to the firm's Litigation and Business Solutions departments and practices mostly in the federal taxation...  |  Read More

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