Changing Approaches to IRS Tax Enforcement: What to Expect


Brad Pees, Nestlé USA


  • Armando Gomez, Skadden, Arps, Slate, Meagher & Flom LLP
  • Matt Lerner, Sidley Austin LLP
  • Starling Marshall, Crowell & Moring LLP

Session Description:

The IRS is on the cusp of significant change. Through implementation of the Taxpayer First Act, the agency seeks to reimagine the taxpayer experience, enhance employee training, and restructure the organization to increase collaboration and innovation. At the same time, tax policy priorities of the Biden Administration and Democratic lawmakers will influence the agency as it pursues its tax enforcement mission. In this session, a team of leading tax practitioners will guide participants through recent changes in the tax enforcement landscape, highlighting how these changes may impact large business tax administration and the enforcement tools used with corporate taxpayers. Panelists will outline significant features of the Taxpayer First Act and provide insights on how the Act’s implementation may impact large business taxpayers. Panelists will also update participants on a variety of LB&I examination procedures, focusing on what’s new and what has remained the same and offering practice tips along the way. Panelists will then shift to the Independent Office of Appeals, providing an overview of recent changes geared toward increasing Appeals independence and discussing how practice in Appeals has changed.

Learning Objectives:

Participants will gain insights into and leave the session with an understanding of: (1) The Taxpayer First Act and how it may impact the IRS’s interactions with large business taxpayers; (2) How the Biden Administration may influence tax policy and enforcement; (3) What has changed and what has remained the same in a variety of LB&I examination procedures and at the Independent Office of Appeals.

Location: Date: March 25, 2021 Time: 10:00 am - 11:15 am