Today’s tax controversy landscape represents a perfect storm of competing factors. In addition to understanding and complying with the complexities coming out of tax reform, the IRS is increasing its enforcement efforts and focusing on large business tax compliance and international tax issues. Audits are becoming more contentious, with both Exam and Appeals seeming to be increasingly unwilling to settle. Revenue constraints are causing states to challenge taxpayers more aggressively. At the same time, taxpayers are required to be more transparent, causing them to be 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 also may be an option for companies wishing to manage their tax risk. In addition, pursuing published guidance from the IRS and Treasury Department may be an important element of a company’s tax risk management strategy, particularly if the uncertainty affects a number of taxpayers.
Effective tax dispute prevention, management, and resolution allows companies to focus on their business operations and objectives as well as reduce the impact on their financial and personnel resources. By obtaining greater certainty and clarity from the IRS and Treasury Department, companies can reduce their risk of controversy along with compliance costs.
PwC’s Tax Controversy and Regulatory Services practice includes several former IRS and Treasury Department officials who are uniquely qualified to advise companies during each phase of an IRS dispute life cycle.
Defense file preparation
Strategic risk assessment/mock audits
ASC 740/UTP reporting review
Private letter rulings
Industry issue resolutions
Participation in Compliance Assurance Process (CAP)
‘Fast track’ appeals alternative