The Obama Administration has made a series of announcements revealing its plans to crack down on corporate tax loopholes and offshore tax havens, and ramp up examinations and enforcement efforts related to multinational corporations based in the United States.  President Obama's budget proposal would increase the tax law enforcement budget from $400 in 2009 to $890 million for 2010, and increase spending on tax law enforcement to $2.1 billion over the next five years. In addition, the  Budget Proposal includes increased penalties for understatement of income and gives the IRS new statutory tools for challenging a taxpayer's treatment of certain transactions.

HOW TO PREPARE FOR AN IRS AUDIT NOTIFICATION

If you receive an audit notice from the IRS, you should immediately contact us to learn how we can develop a legal strategy for responding to the IRS.  By promptly identifying legal and tax issues, organizing your tax and financial documentation, and developing an effective legal strategy, we can put you in the best position to avoid or minimize tax assessments, penalties and interest.

As the company begins planning a legal strategy to an IRS examination, candor and clear communication between the client and tax attorney is critical. If the company has taken any tax positions that the IRS is likely to challenge, it is imperative to discuss these with your tax attorney at your initial meeting to give your attorney adequate time to develop a strategy for responding to the IRS inquiries.

OUR APPROACH TO AN INTERNATIONAL AUDIT

Based on our experience in tax controversy and international tax planning, we try to anticipate upcoming areas of inquiry from the IRS. Each attorney in our tax practice understands that IRS audits can often become protracted, time consuming matters that if not handled properly can be disruptive to business operations. We manage the IRS audit process to enable our client to keep focus on running their business.

Our attorneys help the client assess risk and plan responses to anticipated lines of questions from the IRS. We believe that being prompt, courteous, and responsive to the IRS shows good faith and is generally more likely to result in an acceptable outcome than taking a combative, adversarial approach. However, despite the professional cordiality, we are firm and resolved in defending our client's interests.

COMMON ISSUES IN INTERNATIONAL TAX EXAMINATION

CONTACT US

To speak to an attorney about an inquiry or audit notice from the IRS, please contact us here, or call us at 713.650.9700.

Home  l  About Us  l  Disclaimer  l  Contact l Site Map

Houston  l  The Woodlands