Managing Tax Audits and Appeals 2015

Please click here to view the full conference presentation.

Click below to view individual presentation materials:

• New Audit Paradigm: "Issue-Focused" LB&I Examinations
  Presenter: David B. Blair
• Updates on U.S. Transfer Pricing
  Presenter: David J. Fischer
• California Audit Update
  Presenters: Donald M. Griswold and Jeremy Abrams
• Recent Developments in Tax Accounting
  Presenter: Dwight N. Mersereau
• Employment Tax Updates: Free Lunch in the Tax Court?
  Presenter: Jennifer A. Ray
• Employee Benefits Issues
  Presenter: Joel D. Wood
• Developments in Work-Product Doctrine and Attorney-Client Privilege Issues
  Presenters: Shelley d.A. Leonard and David B. Blair
• Fast Track and Appeals
  Presenters: David B. Blair and David J. Fischer
• LuxLeaks – The EU State Aid Investigations into Multinationals’ Tax Rulings in Ireland, Luxembourg, Netherlands and Belgium
  Presenter: Dr. Salomé Cisnal de Ugarte
• Hot Audit Issues: Parallel Audits; Reopening Audits; and IDR Enforcement and Summons
  Presenter: Shelley d.A. Leonard
• IRS Hires Outside Counsel
  Presenter: David B. Blair

---

Crowell & Moring LLP is pleased to invite you to our twenty-ninth annual seminar on current issues that impact the audit process: MANAGING TAX AUDITS AND APPEALS - 2015.

We are offering the seminar at two locations: on October 1 and 2, 2015 at our Washington, D.C. office, located at 1001 Pennsylvania Avenue, N.W., Washington, D.C., and on October 8 and 9, 2015 at the Hyatt Regency San Francisco, 5 Embarcadero Center, San Francisco, CA. The San Francisco presentation is co-sponsored by the UC Berkeley Center for Law, Business and the Economy.

The attendees are corporate and tax executives and others whose companies have active involvement in the audit and appeals process. Last year, over 175 tax professionals from 150 companies participated in the seminar. We urge you to attend the seminar at either the Washington, D.C. or San Francisco, CA location.

The recent changes to the examination and appeals process, especially during the last year, have been extraordinary. We will consider problems associated with enforcement techniques of the Internal Revenue Service as it reassesses its fundamental approach to corporate audits. The topics that will be discussed include LB&I’s proposals to re-design large case audits to be issue focused and the resulting challenges facing large corporate taxpayers; BEPS, Lux Leaks and developments in transfer pricing audits; issues related to reliance on studies and opinions by outside experts; developments in state and local tax audits; parallel income and employment tax audits; executive compensation and worker classification audits; strategies for dealing with National Office involvement in a hot audit issue; recent developments in partnership tax audits; computing interest on refunds and deficiencies; impact of the Appeals Judicial Approach and Culture (AJAC) initiative on Appeals proceedings; and a legislative update.

The seminar is designed to enable corporate and tax executives to expand their knowledge of key features of the audit process and to focus on opportunities to improve audit outcomes through proper management at the early stages and during the administrative appeals process. The seminar is at an advanced level with emphasis on current developments in the audit and appeals process.

MANAGING TAX AUDITS AND APPEALS - 2015 will be led by Harold J. Heltzer (formerly with the Treasury Department, Office of Tax Legislative Counsel; the Department of Justice, Tax Division; and Adjunct Professor, Georgetown University Law Center) and David Blair (formerly with the Department of Justice, Tax Division and Adjunct Professor, Georgetown University Law Center). Each seminar participant will receive an updated copy of Mr. Heltzer’s treatise, “Coping with IRS Audits.” In addition to panels conducted by several Crowell & Moring tax attorneys and faculty members from the UC Berkeley School of Law (San Francisco seminar), we expect to schedule present and former government representatives who will speak on emerging issues relating to National Office developments, large case audits and recent legislative developments.

Aside from the hotel accommodations, the seminar and accompanying written materials will be provided without charge to participants. If you plan to attend, please join us for the luncheon and the evening cocktail buffet reception that we will host on October 1, 2015 (Washington, D.C.) and October 8, 2015 (San Francisco).

We have reserved a limited number of rooms at the JW Marriott Hotel in Washington, D.C. for the nights of September 30 and October 1, 2015 and the Hyatt Regency in San Francisco, for the nights of October 7 and 8, 2015. For reservations in Washington, please call the hotel directly at 202.393.2000 or 800.228.9290.