BNA/CITE "Resolving Tax Controversies" Conference

Location: Las Vegas, NV

George Hani and Kevin Kenworthy will speak at the "Resolving IRS Tax Controversies" conference. The sessions and topics are listed below.

Overview of the Audit Process

  • IRS Selection of Audits and Programs - LB&I and other Divisions - Quality Examination Program - Random and CAP Audits - Coordinated Industry Issue Audits
  • Audit notification - Taxpayer response to audit notification - Industry Focus Program and rules of engagement
  • IRS Examination Team - composition - Opening Conference and subsequent meetings
  • Procedural issues - statute of limitations extension requests - Information Exchange with foreign governments
  • Information Document Requests (IDRs) and witness interviews - closing the audit

George Hani, Miller & Chevalier, Washington DC

The Tier Issue Program

  • Description of tiers and how tiering affects case resolution - discretionary and mandatory IDRs - settlement authority
  • Select Tier 1 Issues (Active Status): Transfer of Intangibles (Buy Ins/Cost Sharing), Research Credit Claims, Withholding Payments to Foreign Persons, Sec. 199 Deduction
  • "Monitoring" status issues
  • Resolving Tier 1 Issues -- strategy and methods

George Hani, Miller & Chevalier, Washington DC

Litigation Forums and Key Procedures

  • Selecting the best forum: Federal District Court, Court of Claims or Tax Court
  • Considerations in choosing the best forum: ability to pay the proposed tax, choice of law, Judges, procedural differences (depositions, juries)
  • Key aspects of Tax Court litigation – Petition, stipulation process, discovery procedures, burden of proof
  • Trial setting, timing, and use of experts

Kevin Kenworthy, Miller & Chevalier, Washington DC

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