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.

  1. Taxpayers must understand and comply with the complexities of tax reform.
  2. Increased enforcement efforts focus on large business tax compliance and international tax issues.
  3. Audits are more contentious, with both Exam and Appeals increasingly unwilling to settle.
  4. Revenue constraints are causing state and foreign taxing authorities to challenge taxpayers more aggressively.
  5. Increased transparency is exposing taxpayers to more significant tax liabilities.

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PwC's professionals review leading practices when it comes to tax controversy after tax reform, Leading practices to prepare for controversy in the new world order.

How can companies prepare?

Corporate taxpayers can better focus on their business operations and objectives by effectively preventing, managing and resolving their tax disputes. Being proactive around risk mitigation/management and obtaining greater certainty from Treasury and the IRS can help companies reduce their risk of unnecessary controversy and related compliance costs.

Companies should:

  1. Take steps to proactively manage tax disputes when they arise and creatively resolve them in a timely and favorable manner.
  2. Navigate regulatory practices and procedures to manage tax risk.
  3. Pursue published guidance from Treasury and the IRS if the uncertainty affects a number of taxpayers.

How PwC can help

PwC’s Tax Controversy and Regulatory Services practice includes several former IRS and Treasury officials who are uniquely qualified to advise companies during each phase of a tax dispute life cycle.

‘Getting ahead of the issue’ by proactively limiting tax risk

  1. Defense file preparation
  2. Strategic risk assessment/mock audits
  3. ASC 740/UTP reporting review
  4. Private letter rulings
  5. Pre-filing agreements
  6. Closing agreements
  7. Industry issue resolutions
  8. Participation in Compliance Assurance Process (CAP)

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Streamlining/shortening the audit process by resolving issues at the lowest level

  1. Negotiate scope/timing of audit
  2. Advise best practices for answering document requests and managing privilege claims
  3. Assist with employee interviews
  4. Develop taxpayer presentations
  5. Resolve issues at the examination level
  6. Elevate issues ‘up the chain’ at taxing authority, when appropriate

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Analyzing litigation hazards, developing defense strategies, and advocating for successful dispute resolution

  1. Administrative appeals
  2. ‘Fast track’ appeals alternative


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Kevin Brown

Kevin Brown

Principal, Tax Controversy and Regulatory Services Leader, PwC US

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