Tax Executives Institute: Western Michigan Chapter Meeting
Rocco Femia, James Gadwood, Lisandra Ortiz, and Sam Lapin will present to the Tax Executives Institute's (TEI's) Western Michigan Chapter on February 9, 2021.
Gadwood and Lapin will present, "Administrative Practice and Tax Controversy Update." This presentation will address recent important developments in Treasury and IRS guidance and court decisions relating to tax controversy and administrative practice before the IRS. Topics will include recent changes in the LB&I examination process such as the Large Corporate Compliance Program and LB&I campaigns and updates from the IRS Independent Office of Appeals.
Femia and Ortiz will present, "Introduction to APAs and Competent Authority Requests," which will provide an overview of the IRS Advance Pricing and Mutual Agreement Program, advance pricing agreements, and competent authority requests. Topics will include factors to consider in determining whether to pursue these options, best practices for interacting with the IRS and foreign tax authorities, and pitfalls to avoid to preserve access to these options.