Tax controversy and regulatory services (TCRS)

Proactively preventing, managing and resolving tax disputes to help companies reduce their risk of unnecessary controversy and related compliance costs.

Who we are

The TCRS team is composed of former IRS and Treasury officials who are uniquely qualified to advise companies during a tax dispute. Our goal is to allow corporate taxpayers to focus on their business operations and objectives by effectively preventing, managing and resolving their tax disputes. By being proactive around risk mitigation/management and obtaining greater certainty from Treasury and the IRS, companies can reduce their risk of unnecessary controversy and related compliance costs.

Meet the team

86% of tax leaders expect an increase in demand for global tax transparency in the next few years, which could lead to greater reputational risk and increased tax controversy for businesses.

What we do

Our team is uniquely positioned to advise companies during each phase of a tax dispute life cycle. Explore our offerings:

‘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)

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

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

  1. Administrative appeals
  2. Fast track’ appeals alternative


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Contact us

Kevin Brown

Kevin Brown

Principal, Tax Controversy and Regulatory Services Leader, PwC US

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