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2021 76th Annual Conference


TUES07 - TCJA Audits Issues and Trends


Oct 26, 2021 11:00am ‐ Oct 26, 2021 12:00pm

Description

The 2017 Tax Cuts and Jobs Act (TCJA) ushered in the most sweeping tax law change in more than three decades, with 86 provisions that modified, added to, or repealed business and international taxes. After three challenging years of implementing the TCJA, the IRS now faces the critical task of administering and ensuring compliance with the law. Informed by lessons learned from TEI members in the CAP program who have undergone IRS examinations of TCJA issues, our panel of leading practitioners will engage in an interactive dialog, covering topics such as, the multiple facets of section 965 transition tax examinations (e.g., reporting requirement compliance, structuring to limit E&P, characterization issues, and compliance recalculations); GILTI high-tax-exemption issues; FDII documentation requirements; select issues involving the base erosion and anti-abuse tax; overview of relevant IRS campaigns; and the interplay of TCJA issues with state and local taxes.

At the conclusion of this course, participants should:

  • Be aware and have a more informed understanding of the multiple facets of section 965 transition tax examinations; 
  • Better understand GILTI high-tax-exemption issues; 
  • Better understand FDII documentation requirements and how they may be challenged in an examination; 
  • Identify and understand base erosion and anti-abuse tax issues that may be relevant to their employers’ returns; 
  • Identify IRS campaigns that may have application to their employers’ returns; and 
  • Have a more informed understanding of the interplay of TCJA issues with state and local tax returns.

Moderator(s):

Speaker(s):

Tags: IRSAA

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