United States

Tax Audits and Disputes

Stay informed about tax dispute issues and alternative dispute resolution options.

KPMG’s Tax Dispute Resolution (TDR) Services network is a team of experienced professionals from all areas of tax who work with clients to help prevent disputes before they arise and resolve those matters that are subject to challenge by the taxing authorities.



Webcast Replay: The IRS and the Administrative Procedure Act

In this Webcast, KPMG tax professionals provide an introduction to the Administrative Procedure Act’s (APA) notice and comment requirements, survey APA current challenges to IRS rules and regulations, and consider the role APA will play in the world of tax controversy. 


> Launch replay here (original airdate: January 22, 2018)


The IRS and the APA: Denial Is Not a Strategy

In this article, Tom Greenaway of KPMG's Tax Dispute Resolution Network surveys the many Administrative Procedure Act challenges to Treasury regulations. This article was originally published in the January 8, 2018 issue of Tax Notes.


Read the article here.


Webcast Replay: A Deep Dive into IRS R&D ASC 730 Directive and What it Means for You

In this Webcast, senior-level professionals from KPMG's Washington National Tax and Research Credit Services practice present an overview of the recent LB&I Directive, as well as discussing:

  • How to determine QREs under the Directive 
  • Practical challenges and insights to date
  • New recordkeeping requirements
  • Recent developments
  • How to assess the potential benefits and risks of the Directive

> Launch replay here (original airdate: Nov 30, 2017)


The New Centralized IRS Partnership Audit Regime

Effective tax years beginning January 1, 2018, a new centralized IRS partnership audit regime will transform partnership audits and the assessment and collection of tax, affecting all taxpayers that conduct business through partnerships now and in the future.

Learn more



Tax Dispute Resolution Quarterly, Winter 2018

This magazine aggregates hot topics, uncovers dominant trends, and offers value-added insight from our TDR professionals.

Articles featured in the winter 2018 issue include:

  • Partnership disguised sale rules… changing again?
  • Guidance options for new section 1446(g) withholding
  • IRS and APA: Denial is not a strategy
  • Will the Supreme Court overturn Quill?
  • How U.S. BEAT applies to inbound companies



Webcast Replay: 9100 Relief for Missed Tax Elections: What You Need to Know

This Webcast addresses the various relief opportunities for late tax election filing, specifically the section 9100 relief. Topics discussed include:

  • An understanding of 9100 Relief, including when it is available
  • The applicable requirements & procedures to obtain 9100 Relief
  • Misperceptions regarding the ability to obtain 9100 Relief
  • The various alternative late election relief procedures 
(Original airdate: September 12, 2017)

Webcast Replay: Understanding LB & I Campaigns

In this Webcast, Tina Meaux,  assistant deputy commissioner, Compliance Integration, Large Business & International (LB & I) at the IRS and Kathy Robbins, director of the IRS's Enterprise Activities Practice area, speak about the new approach to LB & I campaigns, providing answers to many questions on how they will operate and what a corporate taxpayer should expect.  

(Original airdate: March 7, 2017)

Launch the replay here


Global Tax Disputes Updates

With tax audit activity rising in almost every country, keeping up with trends and developments is more important than ever. Staying informed can be a crucial first line of defense in managing your disputes.

View our Global Dispute Resolution & Controversy Services webpage here


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Video Library


3 Top Tips for C-Level Executives

Discover some tips for C-Level executives when faced with a tax audit or disputes.


Tax Dispute Challenges for Multinationals

Learn about the challenges that multinationals face when dealing with a tax audit or dispute.


Developing Trends and Issues

What are the recent trends and issues related to tax disputes within the United States and abroad?


IRS Update: Enforcement Trends

View IRS enforcement and examination trends from early 2015 and how they may affect large taxpayers.


Need to Know: Alternative Dispute Resolution

Sharon Katz-Pearlman reveals a wide variety of IRS related domestic and international tax issues.

Contact Us


Sharon Katz-Pearlman

Principal in Charge, Tax Controversy Services and Tax Dispute Resolution Services, KPMG LLP

Email: skatzpearlman@kpmg.com

View Bio


Mike Dolan

National Director of IRS Policies and Dispute Resolution, Washington National Tax, KPMG LLP

Email: mpdolan@kpmg.com

View Bio

About the TDR Services Network

KPMG’s TDR Services network is a team of experienced professionals from all areas of tax who work with clients to help prevent disputes before they arise and to successfully resolve those matters that are subject to challenge by the taxing authorities.