Strategies for Managing IRS Audits, Disputes, and Tax Litigation

Introduction

Tax controversies arise when taxpayers face IRS audits, disputes, penalties, or litigation. Successfully navigating these challenges requires an understanding of tax law, dispute resolution strategies, and IRS procedures to minimize financial risk and legal exposure.

This 5-day intensive course is designed for tax professionals, corporate tax managers, attorneys, and financial advisors who need to effectively manage tax controversies, negotiate with tax authorities, and represent clients in disputes. Participants will gain hands-on experience through real-world case studies, mock audits, and negotiation exercises.

Course Objectives

By the end of this course, participants will be able to:

• Understand the IRS audit process, tax examinations, and red flags.
• Develop strategies for responding to tax notices and disputes.
• Navigate tax settlements, penalty abatement, and IRS appeals.
• Handle criminal tax investigations, fraud cases, and litigation.
• Protect clients from unnecessary financial and legal risks.

Who Should Attend?

This course is ideal for professionals handling tax controversies, IRS disputes, and audit representation, including:

• Tax attorneys and legal advisors.
• CPAs and Enrolled Agents (EAs) representing clients in audits.
• Corporate tax managers and CFOs dealing with tax compliance**.
• Forensic accountants specializing in tax fraud investigations.
• Financial planners and consultants advising clients on tax risks.

Course Outline

Day 1: Understanding Tax Controversies & IRS Audits

• Types of tax controversies: Audits, disputes, appeals, and litigation.
• How the IRS selects taxpayers for audits (DIF scores, whistleblowers, AI analytics).
• Common IRS audit triggers: Large deductions, offshore accounts, business expenses.
• IRS examination process: Correspondence, field, and office audits.
• Taxpayer rights and obligations during an audit.

Workshop: Responding to an IRS audit notification and preparing for an audit defense.

Day 2: Strategies for Handling IRS Disputes & Appeals

• How to respond to IRS tax notices and assessments.
• Statute of limitations for audits, collections, and refunds.
• IRS appeals process and administrative dispute resolution.
• How to request penalty abatement and tax debt relief.
• Offer in Compromise (OIC) and installment agreements.

Case Study: Negotiating a tax settlement for a small business under audit.

Day 3: Criminal Tax Investigations, Fraud Cases, and Litigation

• Recognizing signs of tax fraud and criminal liability.
• Handling IRS Criminal Investigation Division (CID) inquiries.
• Tax evasion vs. tax avoidance: Legal implications.
• Defending clients in tax fraud cases.
• How tax litigation works in U.S. Tax Court, Federal Court, and Appeals Courts.

Scenario Analysis: Responding to a tax fraud investigation by the IRS.

Day 4: International Tax Compliance & Cross-Border Controversies

• FBAR and FATCA compliance for offshore accounts.
• OECD tax transparency standards and BEPS enforcement.
• Handling tax disputes for multinational corporations and expatriates.
• Transfer pricing audits and international tax avoidance cases.
• IRS Voluntary Disclosure Program for offshore assets.

Case Study: Resolving an international tax dispute involving foreign bank accounts.

Day 5: Advanced Tax Controversy Resolution & Final Capstone

• Alternative dispute resolution (ADR) in tax cases.
• Navigating IRS collection enforcement (levies, liens, asset seizures).
• Best practices for preventing future tax disputes.
• Technology and AI in tax compliance and risk assessment.
• Final Capstone: Participants develop a tax defense strategy for a complex tax case.

Conclusion & Certification

Participants who complete the course and pass the final assessment will receive a Certification in Tax Controversy Resolution, recognizing expertise in IRS audits, dispute resolution, and tax litigation strategies.

Program Benefits

• Expert-Led Training – Learn from tax lawyers, forensic accountants, and IRS dispute specialists.
• Hands-On Learning – Engage in mock audits, case studies, and tax litigation simulations.
• Strategic Defense Skills – Strengthen IRS dispute resolution and negotiation tactics.
• Global Tax Compliance – Learn international tax controversy management.
• Career Growth – Gain an edge in corporate tax, forensic accounting, and legal tax defense.

Career Opportunities After Certification

• Tax Controversy Specialist – Representing clients in IRS disputes and litigation.
• Corporate Tax Risk Manager – Managing tax compliance and audits for businesses.
• Tax Defense Attorney – Handling criminal and civil tax cases.
• Forensic Tax Accountant – Investigating fraud and tax evasion cases.
• IRS Audit Defense Consultant – Advising clients on tax dispute strategies.