IRS Hot Topics: Enforcement Priorities and Tactics

April 12, 2016

Join our panel for a discussion of recent IRS developments including partnership audit reform, increased government enforcement efforts in cross-border transactions and employment issues. Our attorneys will discuss timely issues including:

  • IRS use of audits as pre-litigation discovery, including summonses, depositions and e-discovery requests
  • Increased focus on partnerships, partnership examinations on the rise, new rules to take effect in 2018
  • International enforcement
    • Continued challenges to transfer pricing structures, including a pending appeal of the Altera case
    • Scrutiny of inventory purchasing structures and other subpart F planning strategies
    • Review of transfers of IP offshore
  • Focus on employee versus independent contractor status
  • Changing face of attorney-client privilege in tax disputes


CLE Information

For more information or to RSVP contact: Ropes & Gray Events