Also IRS Update (What s Hot and What s Not) About the Speaker
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1 The Anatomy of a Federal Income Tax Paul Tew, Senior Manager DHG Tax Also IRS Update (What s Hot and What s Not) 1 About the Speaker Paul Tew, Senior Manager IRS Practice & Procedure Services Member DHG s IRS Practice and Procedures Group Former IRS agent and team manager 38+ years of IRS experience Extensive experience in the international tax area, including transfer practice Spent majority of IRS career as revenue agent and team manager working in international tax Examined mid-size and large corporations with significant cross-border transactions Identified and developed transfer pricing issues on a large multi-national company largest tax dispute resolution in IRS history 2 DHG Birmingham CPE Seminar 1
2 The IRS Mission to provide America s taxpayers top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all." 3 This mission depends on a voluntary compliance system 4 DHG Birmingham CPE Seminar 2
3 Paying tax is statutory the Internal Revenue Code Reporting income and computing the correct tax liability is voluntary 5 Voluntary compliance doesn t always work as envisioned 6 DHG Birmingham CPE Seminar 3
4 Under-reporting of income 7 Overstatement of deductions 8 DHG Birmingham CPE Seminar 4
5 Selective memory loss 9 So there s a necessary enforcement process 10 DHG Birmingham CPE Seminar 5
6 Types of Audits Correspondence audits AUR program audits Office audits Field audits Small business/self-employed audits Large business & International audits 11 The ultimate enforcement tool The IRS Criminal Investigation Division 12 DHG Birmingham CPE Seminar 6
7 The probability of your business being examined increases with asset size Audit Rates in FY2016 Internal Revenue Service Data Book, IRS pre-examination tools 14 DHG Birmingham CPE Seminar 7
8 IRS pre-examination tools Regulatory filings Company website Internet IMS (Issue Management System) IDRS (Integrated Data Retrieval System) Trade publications 15 The audit chronology Return selection Appointment letter/pre-contact IDR Initial contact/opening conference Risk assessment plan Plan execution Closing 16 DHG Birmingham CPE Seminar 8
9 The opening conference 17 The time and place of examination 18 DHG Birmingham CPE Seminar 9
10 Identification of the issues (LUQs) 19 The IDR process 20 DHG Birmingham CPE Seminar 10
11 Agreement & Closing 21 Appeals 22 DHG Birmingham CPE Seminar 11
12 How things fall apart (And what to do about it) 23 Polling Question What Causes An IRS Audit to Head South? 1. Disagreement with the Facts 2. Disagreement with the Law 3. A Zombie Apocalypse 4. Actions of the Examining Agent 24 DHG Birmingham CPE Seminar 12
13 25 The opaque agent 26 DHG Birmingham CPE Seminar 13
14 The confused agent 27 The disappearing agent 28 DHG Birmingham CPE Seminar 14
15 The slow agent 29 The selectively deaf agent 30 DHG Birmingham CPE Seminar 15
16 The make up the rules agent 31 The dangerously competent agent 32 DHG Birmingham CPE Seminar 16
17 The fair and equitable agent 33 The mean, nasty, manipulative, fire-breathing monster agent 34 DHG Birmingham CPE Seminar 17
18 How to put the brakes on an audit gone bad (keywords) 35 Transparency 36 DHG Birmingham CPE Seminar 18
19 Collaboration 37 Substantially correct 38 DHG Birmingham CPE Seminar 19
20 Reasonableness 39 The Bill of Rights 40 DHG Birmingham CPE Seminar 20
21 Flexibility 41 Representation 42 DHG Birmingham CPE Seminar 21
22 What s hot at the IRS 43 LB & I audit campaigns 44 DHG Birmingham CPE Seminar 22
23 Private debt collection 45 Charitable Contributions Deduction 46 DHG Birmingham CPE Seminar 23
24 New Partnership Audit Rules 47 Tax Reform 48 DHG Birmingham CPE Seminar 24
25 What s not hot at the IRS 49 Deep cuts 50 DHG Birmingham CPE Seminar 25
26 Excessive workload 51 Mass exodus of experienced personnel 52 DHG Birmingham CPE Seminar 26
27 Retirements 53 Hiring freeze 54 DHG Birmingham CPE Seminar 27
28 The need to use limited resources effectively 55 IRS Future State 56 DHG Birmingham CPE Seminar 28
29 57 Paul S. Tew Senior Manager Dixon Hughes Goodman LLP dhgllp.com 58 DHG Birmingham CPE Seminar 29
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