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2022 72nd Midyear Conference

T08 - Navigating the Evolving Landscape of IRS Audits – Views from the Trenches

Mar 22, 2022 1:00pm ‐ Mar 22, 2022 2:00pm


Tax professionals who manage audits and appeals are currently facing a wide range of unprecedented challenges. This session brings together an accomplished panel of in-house tax professionals and the IRS’s former Chief Counsel to share their experiences and offer best practices on a variety of IRS practice and procedural topics, such as the current IRS Exam environment and resource constraints; issues arising from TCJA-related audits; areas of substantive focus outside the TCJA; LB&I’s new focus on partnerships (including the LPC Program and new loss limitation campaigns); policy uncertainty impacting examination progress; involvement of IRS Counsel in examinations (including use of formal and informal procedures and the new streamlined ruling process); and recent developments at the Independent Office of Appeals.

At the conclusion of this course, participants should:

  • Be aware of the operational challenges Exam is facing in the current environment and best practices for responding;
  • Understand changes in how Exam is risk assessing return positions and how it could impact examinations;
    Be aware of difficulties taxpayers are facing in examinations of TCJA issues and be better prepared for them;
  • Understand procedural aspects of LB&I’s LPC Program and new loss limitation campaigns and how they may impact examinations;
  • Understand how the involvement of IRS Counsel impacts examinations and how to effectively manage such issues;
  • Understand recent changes at the Independent Office of Appeals and how they may impact future cases




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