IRS Hot Topics: Enforcement Priorities and Tactics
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
For more information or to RSVP contact: Ropes & Gray Events