Tax controversy and regulatory services (TCRS)

Focus on your business operations and objectives

Companies may be able to reduce their risk of unnecessary controversy and related compliance costs by being proactive around risk mitigation and management and obtaining greater certainty from Treasury and the IRS. By receiving guidance and resolution from Former IRS and Treasury officials, companies can work to proactively prevent, manage and resolve tax disputes to help companies reduce their risk of unnecessary controversy and related compliance costs. This is where PwC comes in. 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.

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.

Source: PwC Pulse Survey

Working together

Achieve successful outcomes, minimize risks, and maintain compliance with tax laws and regulations. Our Tax Controversy and Regulatory Services team and comprehensive range of services 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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