(The Transfer Pricing Examination Process was recently updated by the Department of Treasury – June 2018. TaxConnections posts this valuable eight part a series to keep you informed of these changes.)

C. Appeals Phase
As a best practice, the issue team will begin preparing the pre-Appeals presentation immediately after closing the case. Upon contact from Appeals that the case has been assigned, the issue team should:
• Request a pre-Appeals conference using Forms 3198 and 4665
• Contact the Appeals Officer and request examination’s presence at the taxpayer’s portion of the presentation
• Determine which LB&I team members should attend the pre-Appeals conference
• Determine the roles and responsibilities of the issue team members
• Hold mock presentations to prepare for the pre-conference meeting
• Hold the Appeals pre-conference meeting

Request a post-Appeals Conference and attend the meeting. The issue team should:
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