Crm minnesota 4 27-2011

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  • 1. Michael GregoryMichael Gregory Consulting LLC for CRM Minnesota April 27, 2012
  • 2.  Michael Gregory, Chief Manager, Michael Gregory Consulting LLC since September 12, 2011 Formerly IRS 28 Years as Engineer and Valuer, Manager, Operations Team Lead, Controller, Acting Assistant District Director, Territory Manager ASA, AVA, MBA, PE, Qualified Neutral Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 3.  Risk Management with IRS Alternative Dispute Resolution - Mediation Strategic Planning Could be of Service to You and Your Clients mg@mikegreg.com 651-633-5311 Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 4.  The opinions presented here are those of Michael Gregory. Michael Gregory does not represent the IRS. Any opinions presented in this seminar are those of the author and do not represent an official position of their current or previous employers. This material is offered for educational purposes only. The author and his employer expressly disclaim any liability, including incidental or consequential damages, arising from the use of this material or any errors or omissions that may be contained in it.Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 5.  Background on IRS Mediation Officially at the IRS Some Case Examples of Conflicts Mediation Defined and Applied from a Practical Perspective at the IRS DiscussionMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 6.  What Does the IRS look like to you? Mailbox with a slit to receive your tax return? A tax collector and what does that mean? An agency there to help you? Taxes are what we pay for a free society thank goodness the agency promotes voluntary compliance?Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 7.  Eleven Divisions – Note all of this material on the IRS can be obtained at irs.gov Compliance – Four Divisions Appeals Counsel – IRS and DOJ Tax Litigation Division Taxpayer Advocate Office Equity Diversity and Inclusion Others Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 8.  Businesses Starting a Business Operating a Business Closing a Business Employer ID Numbers Small Business Events Industry Professions Audit Technique Guides – Aerospace to Wine Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 9.  Six Industries and One Support Function CTM, FS, HMT, NRC, RFPH, GHW, Field Specialists  Engineering and Valuation  Employment Tax  Computer Audit Specialists  Financial Products Counsel Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 10.  Examination  General  Estate and Gift  Classification Process  Owner Collection Counsel Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 11.  ESOP’s Related for Profit Entities Gifts in Kind Services Provided Reasonable Compensation Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 12.  Case Closes Out of Examination Unagreed and Goes to the Internal IRS Appeals Divisions Goal to Settle Cases 85% Target (Historically) Independent Ex Parte Rules Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 13.  IRS Office of Chief Counsel  Appointed by the President  Operations  Technical  All Non Litigation Work (legislative, regulation, interpretation)  Corporate  International  Technical Advice IRS Division Counsel IRS Special Trial Counsel DOJ Tax Litigation Division Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 14.  At Least One in Every State –St. Paul Independent Organization to Help Taxpayers with Problems Address – economic harm, delay over 30 days, not received by date promised by the IRS Free, Confidential, Listen, Help 1-877-777-4778 or TTY/TTD 1-800-829-4059;Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 15.  Formerly Equal Employment Opportunity and Diversity Mike on EEOD Advisory Counsel for the Commissioner for Four Years Promote Diversity and Address Diversity Issues Example LaterMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 16.  Who Owns the Case? Who Manages the Case? Let’s Discuss Some ExamplesMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 17.  SBSE Examination Case with E&G on Exam SBSE Examination Case with Counsel SBSE Case at Appeals TEGE Case with Related Entities  Credit Counseling, Reasonable Compensation  Hospitals, Physician Practices, Universities LB&I Stock Options and Stock Valuations LB&I Purchase Price AllocationsMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 18. Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 19.  Officially at Appeals – Hazards of Litigation  Revenue Procedure 2009-44  Fast Track Mediation• Officially with SBSE - Recommendations IRSAC Unofficially During Examination – Manager  Legally Focused  Client Based Specialists Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 20.  Budget Division Chiefs Research Credit 4 Days Valuation Issue Relief From Royalty Method  Royalty Rate, Discount Rate, Time Period Reasonable Compensation EEOD Manager EmployeeMichael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 21.  Know Who Your Working with at the IRS Understand the Role of Participants Seek to Understand Interests  Model: Facts, Issues, Feelings, Interests, Alternatives, Solutio ns either Client Based or Legally Focused Do Not Be Afraid to Ask Questions Consider Options  Ask for Appropriate Party  Ask to Elevate in Management as a Neutral Party Given Ownership of the Issue by the RA or ETA Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 22.  IRS official and unofficial workings at the IRS Classification Technical Chapters on Engineering and Valuation Issues Issue Resolution and Mediation Strategic Thinking and Growth Areas for Business Valuers and Mediators Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 23.  Realizing Many Issues in Corporate Tax are Gray by Design Listening to Both Parties Looking for Common Ground by Asking Questions Client Based Focus Remaining Neutral Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011
  • 24. Michael Gregory Consulting LLC www.mikegreg.com © 4/27/2011