Ticked Boxes? –
IT IS THEREFORE clear that it cannot simply be accepted that ticking the correct boxes and submitting the required supporting schedules is sufficient. A taxpayer is required to provide the IRS with all the material facts which would influence their decision on how the transaction should be treated for tax purposes. The crucial time to provide this information is before the original assessment is issued. The best opportunity is therefore in the tax return.
Cooperation between Senior Management and the Tax Manager –
TRANSPARENT TAX COMPLIANCE means that the IRS will find it very difficult to issue an additional assessment after the expiry of the statutory final and conclusive period to close an original assessment. This is a strategy worth considering but can only be accomplished when all the key decision makers within an organization (for instance, the CEO, the BO/CFO, and the tax manager ), the role players in a particular transaction, and the audit committee take an active interest in and work together with the tax department in achieving this.