Tax Controversy Services
Current trends suggest that multinational organizations will continue to spend more time and resources managing tax controversies in both their local and foreign markets. Tax authorities are sharing information about companies and focusing increasingly not just on the technical merit of a tax position but also on its implementation. Deloitte's tax controversy teams include former tax authority officials, alternative dispute resolution specialists, and in many countries, tax litigation specialists who can assist multinational businesses through the phases of the tax controversy cycle.
- Interest Analyzer
- Examination Services
- Appeals Assistance
- Tax Controversy Technology
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Interest Analyzer Services
Calculating interest on tax deficiencies and refunds can be particularly complex, and miscalculations by the IRS are not uncommon. Miscalculations, even small ones, can result in significant overcharges of interest payable to the IRS or undercharges of interest payable to a taxpayer. Deloitte’s Tax Interest Analyzer Services are designed to help address issues with respect to IRS interest assessments and IRS interest refunds. In performing reviews, our team considers federal taxes, including income, employment, and excise tax. State income tax accounts can be considered as well. Our Tax Interest Analyzer Services can help taxpayers review interest associated with their tax payments and/or tax refunds and analyze whether any monies might be owed to them.
Our Tax Interest Analyzer Services team is comprised of experienced specialists in IRS account analysis and interest computations and is supported by our national Tax Controversy Services practice, which includes more than 80 professionals with wide-ranging IRS experience.
Should the IRS initiate an examination, Deloitte can assist during the process, from analyzing pre-examination risk exposure and planning for the opening conference to investigating possible opportunities for improvements post-exam. We provide day-to-day assistance, provide representation at IRS meetings, assist with document requests and analysis of proposed adjustments, advise you in addressing issues, and calculate final tax and interest amounts. We also assist as you track progress, manage statute of limitations, accelerate and close examinations, and accelerate appeals review (including appeals consideration under the IRS Fast Track Settlement program).
The objective of the IRS’s issue management strategy is consistent resolution of compliance issues. Some practitioners have noted less flexibility and greater reliance on uniform settlement terms recently—including Appeals Officers coming to the table with settlement terms already defined. To protect their interests, taxpayers should interact directly with Appeals decision makers.
First-hand experience with IRS proceedings helps us offer informed perspectives on the strengths and weaknesses of your company’s position—as well as the government’s position—in a dispute. From planning to closing proceedings, we can support you throughout the appeals process. We provide advanced appeals planning; preparation, review, and case analysis for protests; and representation at appeals conferences or in alternative dispute resolution procedures.
Tax Controversy Technology
As global tax authorities streamline their processes and demand more information from taxpayers in shorter timeframes, managing tax examinations grows more challenging each day. Never before has it been so important to be efficient, accurate, and consistent in the way you manage your global tax controversy processes. Traditional approaches used by tax department professionals such as spreadsheets, network drives, binders, and file cabinets aren’t keeping pace. In response to the growing complexity of tax examinations, Deloitte has developed an innovative tool, Tax Controversy Manager (TCM). Deloitte’s web-based and scalable TCM harmonizes the tax audit process across jurisdictions for virtually any type of tax controversy. TCM enables you to prepare for and manage your tax controversy processes and related documentation across multiple tax audits, and provides you with domestic and global transparency, real-time knowledge sharing, and clear visibility to the related management and analysis metrics and supporting documentation.