IRS controversy experience can help speed conflict resolution
The IRS continues to focus on businesses, international transactions and high-net-worth individuals in its effort to identify tax compliance errors and underpayments. As a result, tax controversy services are in high demand. Whether you are seeking to resolve a known controversy or mitigate future risk, RSM understands how to navigate the IRS and can help clients avoid risk and resolve disputes.
Specific tax controversy services include:
- Pre-filing representation and assistance. Resolving issues in a less adversarial environment can offer better overall results in less time than the traditional IRS examination process. RSM can help minimize tax risk in your return by utilizing pre-filing resolution programs tailored to your situation.
- IRS controversy representation. Don’t face the IRS alone. Our tax controversy professionals represent clients in federal tax disputes before the IRS, including those involving fast track settlements, IRS appeals, mediation and arbitration.
- Compliance solutions. Ignoring certain compliance failures or issues can leave you open to lengthy IRS audits, penalties and worse. We can approach the IRS and propose a resolution (initially on an anonymous basis), which may increase your ability to reach an expedited and favorable conclusion.
- Penalty prevention and abatement. Our tax controversy professionals draw on years of experience to advise on strategic penalty prevention. Where penalties result from late filing or late payments, our tax controversy team can offer sound strategies to obtain penalty abatements and assist you in preventing such penalties in the future.
- Interest computation and review services. Interest assessments are complex and can occur long after the IRS completes its examination and assesses the tax. We can review account activity across years, returns and types of tax to identify and resolve IRS errors, including overassessments of deficiency interest and under-refunds of credit interest.
- IRS account management. Do you know whether there are errors in your IRS account? Uncorrected errors can occur when the IRS adjusts tax payments or credits, assesses penalties or interest, or fails to properly record entity information. Our team can conduct a detailed review to of your company’s IRS accounts, interpret account transcripts and isolate account problems.
- Entity classification issues. Mergers and acquisitions can result in entity classification issues where taxpayer identification numbers, fiscal-year ends or common parent identities do not match the IRS’s records. Working with our M&A professionals we can assist you in resolving these matters quickly and efficiently.
Regulations implementing the BBA rules were revised to conform to the Technical Corrections Act of 2018, other revisions also made.
Former shareholders were found liable for tax from asset sale as transferees because the subsequent stock sale lacked economic substance.