Key takeaways
Host: Rosemary Sereti, managing director, Deloitte Tax LLP
Presenters: Jason Dimopoulos and Debra Estrem
The IRS has indicated it is hiring thousands of agents as it gears up for a significant increase in the number of audits of large multinational taxpayers and high-income individuals. How can you prepare for this upcoming surge in enforcement, and what actions should you take to respond to tax controversy challenges that may be on the horizon? We’ll discuss:
- An IRS operational update to include service-wide hiring initiatives
- What taxpayers and practitioners may expect from examinations this year, including recent issues and trends
Meet the speakers

Rosemary Sereti
Rose brings more than 30 years of Internal Revenue Service (IRS) experience to identifying and resolving international and domestic tax compliance issues for our clients. Rosemary is a managing director with Deloitte Tax LLP's Washington National Tax and Tax Controversy Services practice groups. Upon joining Deloitte in 2017, Rosemary has advised and represented clients in a variety of tax controversy matters including audit inquiries and assisting clients in successfully resolving issues at Examination and Appeals Immediately prior to joining Deloitte, Rose was the deputy commissioner for the Large Business and International (LB&I) division at the IRS, where she supervised over 5,000 tax professionals and staff and spearheaded notable initiatives. She led the design and implementation of the new compliance campaign process, formed a cross-functional implementation team to govern and provide strategic oversight for the new partnership audit procedures, and developed a strategic plan to redesign the Compliance Assurance Program and the legacy Coordinated Industry Case Program. Her other IRS roles included industry director for Financial Services, director of International Individual Compliance, and deputy director for pre-filing and technical guidance. In all these roles, she worked with taxpayers and trade associations to identify, address, and resolve significant international and domestic tax issues across a wide range of industries and tax return filing populations. In addition to her leadership and management credentials, Rose was a 2017 recipient of the IRS Treasury Leadership Legacy Award and a previous recipient of the IRS Commissioner's Award. Rose has authored articles for Tax Executive and The Tax Adviser and provided content for Financier Magazine and Tax Controversy Leaders Guide. She is a frequent speaker at local, regional, and national Tax Executive Institute events, the New York University annual Tax Controversy Forum, and at many programs organized by Deloitte. Rose holds a BS in accounting from Quinnipiac University and an MS in taxation from University of New Haven.

Debra Estrem
Debra is the National Private Wealth Tax Controversy leader for Deloitte Tax and advises on Internal Revenue Service (IRS) controversy matters for estates, individuals, tax-exempt entities, and corporations, both US- and foreign-based. She is particularly experienced with valuation, hobby loss, claims, employment tax, and penalties. In addition, she assists in obtaining voluntary disclosure agreements, technical advice and pre-filing agreements, defending IRS examinations, and conducting IRS fast track and regular appeals and post-appeal mediation. She regularly performs IRS readiness projects for individuals and for-profit and tax-exempt entities. Prior to joining Deloitte, Debra worked at the IRS Office of the Chief Counsel, where she litigated a wide variety of individual, estate, corporate, and partnership tax matters. She has more than 20 published US Tax Court opinions. Debra regularly publishes articles and is quoted in the media. She is a frequent speaker at events sponsored by Deloitte and other organizations such as American Institute of CPAs, UCLA Tax Controversy Symposium, Bloomberg BNA lecture series, law firms, and estate planning groups throughout the country. She is an adjunct professor for Golden Gate University. Debra has a BA from University of Washington and a JD from University of California Hastings Law School.
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