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
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.
Outline
- Background of Tier I audit designation
- What it means for an issue to be “Tier I”
- Active and monitoring-status issues
- Recent IRS changes to Tier I policy
- E.g. withholding, transfer pricing, hybrid structures
- What it means for an issue to be “Tier I”
- Lessons learned from recent IRS audits involving Tier I issues
- Issues drawing considerable attention
- Processes to develop facts with IDRs, informal discovery
- Level of interviewing of taxpayer personnel
- Involvement of chief counsel and technical staff
- Level of centralized control
- Recommendations to prepare more effectively for Tier I audits
Benefits
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.
Faculty
George Hani
Member
Miller & Chevalier
He is Vice Chairman of the firm's Tax Department and specializes in administrative appeals of federal tax disputes. He... | Read More
He is Vice Chairman of the firm's Tax Department and specializes in administrative appeals of federal tax disputes. He has broad experience in all IRS appellate programs and previously worked in the Treasury Department's Office of Tax Policy.
CloseJean Pawlow
Partner
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
She is a member of the firm's U.S. and International Tax Practice Group and chairwoman of its Federal Tax Controversy Practice. She has been involved in significant tax litigation matters for more than 20 years and frequently writes and speaks on Tier I issues.
CloseMatthew Lerner
Partner
Steptoe & Johnson
He is attached to the firm's Litigation and Business Solutions departments and practices mostly in the federal taxation... | Read More
He is attached to the firm's Litigation and Business Solutions departments and practices mostly in the federal taxation arena. He has substantial experience in both civil and criminal tax controversies and complex litigation related to tax strategies, and also provides business tax planning. He has written and spoken on IRS tiered issues.
Close