Plan the Factual Gathering Process

TAKE EACH ON-the-radar screen and off-the-radar screen tax risk identified and create a unique file number, file (hard copy and electronic [pdf] copy), and start assembling all correspondence, documents, notes, agreements, opinions, memoranda, and any other relevant information into date order.

Priorities will differ on a case-by-case basis. The factual gathering process is dealt with in more detail in chapter 5 of this special report.

Plan the Analytical and Solutions Process

THE TAX TECHNICIANS who will assess the tax risk of each on-the-radar screen and off-the-radar screen tax risk issue will be determined, to assist in advising how each tax risk issue must be dealt with now and in the future.

Should any real exposures be identified the conclusions will be submitted, with the appropriate advice obtained via the tax team to the audit committee for final decision.

In accordance with Circular 230 Disclosure