Rapid business transformation across the globe and shifting international policy are driving significant changes to organizations’ tax exposure, financial resilience, strategy and management. These factors are shaping how companies across every sector approach the future of tax dispute resolution.
Our latest report draws on an independent survey of 1,200 tax leaders in 10 jurisdictions and across six sectors conducted in late 2021 and insights from our tax disputes and international tax teams.

The Internal Revenue Service has issued final regulations limiting the IRS’s ability to hire private attorneys as contractors. The final regulations, published on 7 September 2021, finalize proposed regulations published on 7 August 2020.

The Internal Revenue Service (IRS) has issued new proposed regulations that would further limit the IRS’s ability to use private attorneys as contractors. The newly proposed regulations, published on 7 August 2020 (“2020 Proposed Regulations”), replace proposed regulations issued in 2018. The 2020 Proposed Regulations are the IRS’s first response to the 1999 passage of the Taxpayer First Act, which barred nongovernmental attorneys from questioning witnesses under oath in summons interviews. The newly proposed regulations forbid the IRS from sharing taxpayer books and records with attorney outside contractors, except under limited conditions. The newly proposed regulations also forbid outside contractors from asking a summoned person’s representative to clarify an objection or an assertion of privilege.