Managing Tax Audits and Appeals 2014

Crowell & Moring LLP is pleased to invite you to our twenty-eighth annual seminar on current issues that impact the audit process: MANAGING TAX AUDITS AND APPEALS - 2014. We are offering the seminar at two locations: on October 9 and 10, 2014 at our Washington, D.C. office, located at 1001 Pennsylvania Avenue, N.W., Washington, D.C. and on October 23 and 24, 2014 at Le Meridien Hotel, 333 Battery Street, San Francisco, California. The San Francisco presentation is 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, California 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 dealing with new challenges facing large corporate audits; navigating recent and pending developments in CAP audits; developments in transfer pricing audits; Advance Pricing Agreements and Competent Authority procedures; filing claims for refund in state and local tax audits; Joint Committee refund procedures; is your taxable year closed; new IDR enforcement policies and summons procedures; executive compensation and worker classification audits; strategies for dealing with National Office involvement in a hot audit issue; recent developments in partnership tax audits; FATCA launch and its implications; computing interest on refunds and deficiencies; and use of experts in Fast Track and at Appeals. 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.

TAX AUDITS AND APPEALS - 2014 will be chaired by the head of our 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.

The program for the seminar and a registration form to express your interest in attending either the Washington, D.C. or San Francisco seminar are enclosed. 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 9, 2014 (Washington, D.C.) and October 23, 2014 (San Francisco).

We will provide a certificate of attendance and other materials to use in seeking continuing education credits.

Please click here to view the complete agenda.

Please click here to register.