With more than $40 billion of additional IRS funding earmarked for enforcement, understanding how to best work with the agency and successfully resolve controversy is critical for in-house counsel and private practice attorneys alike. Fenwick’s Larissa Neumann and Matthew Dimon spoke with James B. Kelly from the IRS, Tom Linguanti, a private practice tax attorney, and Sonja Schiller from Alphabet/Google, about issues surrounding recent trends in tax controversy and litigation. Providing perspectives from private practice, in-house counsel and the chief counsel’s office, they covered several topics pertinent to both litigators and people involved in tax planning and structuring, noting that often successfully resolving controversy begins with good planning. The topics discussed included: (1) the IRS’s increased audit and enforcement budget, (2) increased assertions of penalties, (3) trends in the application of economic substance doctrine, (4) international transfer pricing and regulatory challenges and (5) best practices for tax litigation and planning.
Read the full report on the IFA USA 51st Annual Conference - Tax Controversy Trends panel here.