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Managing Tax Audits and Appeals

October 17-18, 2013 • San Francisco, CA

For the first time this year, we are offering the seminar at two locations: on October 3 and 4, 2013 at Crowell & Moring's Washington, D.C. office, located at 1001 Pennsylvania Avenue, N.W., Washington, D.C. and on October 17 and 18, 2013 at Le Meridien Hotel, 333 Battery Street, San Francisco, California, co-sponsored by the UC Berkeley Center for Law, Business and the Economy. The attendees are corporate and tax executives and others whose companies have active involvement in the audit and appeals process.  Last year, over 175 tax professionals from 150 companies participated in the seminar.  We urge you to attend the seminar at either the Washington, D.C. or San Francisco location.

The recent changes to the examination and appeals process, especially during the last year, have been extraordinary.  The topics that will be discussed include formulating alternative audit and appeals strategies for large corporate audits; handling transfer pricing issues; changes to the Advance Pricing Agreement and Competent Authority revenue procedures; dealing with state and local tax audits; who should be handling your unclaimed property audits; audit issues under the Patient Protection and Affordable Care Act; use of the Administrative Procedure Act to challenge IRS actions and pronouncements; authority to sign on behalf of a corporation or other entity; corporate audits from the perspective of the Large Business and International industry groups; developments in Appeals Office initiatives; computing interest on refunds and deficiencies; recent developments in partnership tax audits; and a primer on new rules of engagement in audits.  We will consider problems associated with enforcement techniques of the Internal Revenue Service as it reassesses its fundamental approach to corporate audits.

The seminar is designed to enable corporate and tax executives to expand their knowledge of key features of the audit process and to focus on opportunities to improve an audit’s outcome through proper management at the early stages and during the administrative appeals process.  The seminar is at an advanced level with emphasis on current developments in the audit and appeals process. 

MANAGING TAX AUDITS AND APPEALS - 2013 will be chaired by the head of Crowell & Moring's tax group, Harold J. Heltzer (formerly with the Treasury Department, Office of Tax Legislative Counsel; the Department of Justice, Tax Division; and Adjunct Professor, Georgetown University Law Center).  Each seminar participant will receive an updated copy of our treatise, “Coping with IRS Audits.”  In addition to panels led by several Crowell & Moring tax attorneys and faculty members from the UC Berkeley School of Law (San Francisco seminar), we expect to schedule present and former government representatives who will speak on emerging issues relating to National Appeals Office developments, large case audits and recent legislative developments.

Aside from the hotel accommodations, the seminar and accompanying written materials will be provided without charge to participants.  If you plan to attend, please join us for the luncheon and the evening cocktail buffet reception that we will host on October 3, 2013 (Washington, D.C.) and October 17, 2013 (San Francisco).

We have reserved a limited number of rooms at the Willard Intercontinental Hotel in Washington, D.C. for the nights of October 2 and 3, 2013 and Le Meridien Hotel in San Francisco, for the nights of October 16 and 17, 2013.  Please make your hotel reservation directly by calling either the Willard Intercontinental Hotel at 202.628.9100 or 866.487.2537 or Le Meridien Hotel in San Francisco at 415.296.2900 or 866.837.4184. 

We will provide a certificate of attendance and other materials to use in seeking continuing education credits.  We hope that you can attend.  If you cannot, please pass this invitation along to another member of your organization who is involved in tax matters.

Please click here to see a full agenda.

Crowell & Moring Participant(s):
Harold J. Heltzer
Partner – Washington, D.C.
Phone: +1 202.624.2565