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Tax controversy and regulatory services (TCRS)
What is the current state of tax controversy?
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.
How can companies prepare?
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.
Why is mitigating/managing risk important?
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.
With an experienced team of former high-level officials at the US Treasury, IRS, and Justice Department, our TCRS team is uniquely qualified to advise taxpayers during each phase of an IRS dispute life cycle. Contact our team today to see how we can help you better accomplish your business and tax objectives.
Related content
IRS reorganizes Large Business and International Division
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IRS's Information Document Request process: How to navigate the IDR process for US-based m...
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Contact us
Kevin Brown
Principal, Co-leader, Tax Controversy and Regulatory Services, PwC US
Tel: +1 (202) 346 5051
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