Tax Controversy

Tax Controversy

Andersen’s tax controversy practice helps clients navigate complex audits and appeals and resolve challenging practice and procedure matters with federal, state, local, and foreign tax authorities. Around the world, tax authorities are scaling up enforcement and tax collection efforts on high-net-worth individuals and large, complex, and high-risk partnerships and corporations. 

In the U.S., IRS is leveraging billions of dollars in new funding and cutting-edge artificial intelligence capabilities to increase examination rates ten-fold on certain taxpayers. IRS has already hired and deployed thousands of new agents, with plans to hire even more, to execute upon new campaigns, programs, initiatives, and projects targeting taxpayers with the highest potential compliance risks.

Our proactive approach to pre-controversy risk mitigation and audit readiness helps clients identify areas that could raise issues and either take affirmative steps to remediate or prepare to respond quickly to information requests. 

When disputes arise, we assist throughout all stages of the examination, including:

• Managing communication, coordinating timeline, and limiting scope with examiners from early stages through closing in pursuit of a “no change” conclusion.
• Negotiating and responding to Information Document Requests (IDRs).
• Conducting technical research and analyses to support tax positions.
• Defending tax positions in response to Notices of Proposed Adjustment (NOPAs).
• Preparing protest letters to IRS Independent Office of Appeals and providing representation.
• Rendering expert testimony, analyses, and other litigation support in judicial proceedings.
• Installment agreements and offers-in-compromise.