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West Coast Managing Tax Audits and Appeals Seminar 2016

Event | 04.19.16, 1:00 AM PDT - 10:30 AM PDT

Address

Marina Del Rey Marriott
4100 Admiralty Way, Marina del Rey, CA 90292

Please join us for the 30th Annual Managing Tax Audits and Appeals seminar. We are offering this program in two locations: Marina del Rey, CA (near Los Angeles) and Washington D.C.



Please click here for the Marina del Rey Agenda.

Please click here for the Washington, D.C. Agenda.

Please click here to access the Marina del Rey presentation slides.

This seminar provides an in-depth analysis of current developments in IRS and state audits and appeals. 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 audit outcomes through proper management at the early stages and during the administrative appeals process. The seminar is at an advanced level. Past attendees include corporate and tax executives and others whose companies have active involvement in the audit and appeals process. Last year, over 150 tax professionals from 90 companies and the government participated in the seminar. Register now to attend the seminar at either the Washington, D.C. or California location.


Recent changes to the examination and appeals process, especially during the last year, have been extraordinary. The topics that will be discussed include:


  • LB&I’s re-design of the audit paradigm and the resulting challenges facing large corporate taxpayers
  • Developments in transfer pricing audits and Competent Authority as a result of the LB&I changes and the OECD’s Base Erosion and Profit Shifting (BEPS) reports
  • Congress’ overhaul of the audit rules for partnerships and how to prepare for the changes
  • Developments in state and local tax audits
  • Developments in tax accounting, Section 199, and the repair regulations
  • The impact of the Appeals Judicial Approach and Culture (AJAC) initiative on appeals proceedings
  • Legislative update, the pending election and tax policy, and potential for lame duck tax changes

The seminar will be led by the Crowell & Moring LLP Tax Group. Each seminar participant will receive an updated copy of the Crowell Tax treatise, “Managing Tax Audits and Appeals”. In addition to panels conducted by several Crowell & Moring tax attorneys, we expect present and former government representatives to speak on emerging issues relating to Chief Counsel developments, large corporate audits, transfer pricing, partnership audits, and 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 reception that we will host on September 22, 2016 (Marina del Rey, CA) and September 29, 2016 (Washington, D.C.).

We have reserved a limited number of rooms at the Marina del Rey Marriott (tel. 310.301.3000) for the night of September 22, and the JW Marriott Hotel in Washington, D.C. (tel. 202.393.2000 or 800.228.9290), for the nights of September 29 and 30. For reservations, please call the hotels directly. Please note that rooms are filling up fast and the room blocks may be sold out. However, we have plenty of other hotel options nearby.

For questions regarding this seminar, please e-mail crowelltax@crowell.com.

For more information, please visit these areas: Tax, International Tax, Tax Controversy, State and Local Tax, Litigation and Trial, Corporate and Transactional

Insights

Event | 02.20.25

Has the Buss Stopped? Recoupment Today

Has the Buss Stopped? Recoupment Today: In 1997, the California Supreme Court decided Buss v. Superior Court. In Buss, the court concluded that a liability insurer that defended a mixed action could seek reimbursement from the insured for the defense costs associated with the claims that were not even potentially covered. Since then, numerous courts have held that insurers are entitled to recoup their defense costs associated with uncovered claims or causes of action. On the other hand, a significant number of courts have rejected insurers’ right to recoupment, at least in the absence of a policy provision granting the insurer that right. Some commentators have even suggested that the current judicial trend might be away from permitting insurers to recoup their defense costs. Is that correct? Has the Buss stopped? This panel of coverage experts will analyze insurers’ claimed right to recoupment today, and offer their perspectives on what the law on recoupment should perhaps be and might be in the future.