Today’s tax controversy landscape represents a perfect storm of competing factors. The IRS is increasing its enforcement efforts, and focusing on large business tax compliance and international tax issues, for example, the new mandatory Information Document Request summons procedures. Audits are becoming more contentious, and both Exam and Appeals seem increasingly unwilling to settle. States are challenging taxpayers more aggressively due to revenue demands. At the same time, taxpayers are required to be more transparent (e.g. ASC 740 and UTP reporting), and consequently are more exposed on significant tax liabilities.
Companies can minimize disruption to their business operations, by taking steps to prevent tax disputes, proactively manage them when they arise, and creatively resolve them in a timely and favorable manner, without the need for costly and unpredictable litigation. Navigating regulatory practices and procedures, such as pursuing published guidance from the IRS and Treasury Department, may also be an option for companies to manage their tax risk.
Limiting and resolving disputes effectively allows you to focus on your business as well as reduces the impact on your resources and saves you money.