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POLITICO Quotes Charles Ruchelman: Can't Fight the IRS? Don't Tell Microsoft

January 12, 2015, POLITICO Pro
POLITICO Pro quoted Charles Ruchelman regarding a dispute between Microsoft and the IRS on whether the company pushed profits offshore to escape taxes. For the complete article, please visit POLITICO Pro's website (subscription required).

Excerpt taken from the article.

"What's going on here with Microsoft — with billions of dollars at stake — is rare," said Charles Ruchelman, a former IRS and Justice Department tax official now at Caplin & Drysdale. This "is not, if you are a company, where you necessarily want this to go."

...

Stricter audits

The spat comes as the agency implements a new system for auditing, one that lawyers say is not beneficial for their corporate clients because it gives agents less leeway to compromise.

The changes require agents to take prescribed steps within certain time frames when seeking information — with the final step being issuing a summons.

"This process is mandatory and has no exceptions. It requires (Large Business and International) managers at all levels to be actively involved early in the process and ensures that Counsel is prepared to enforce IDRs [information document requests] through the issuance of a Summons when necessary," a February 2014 memo reads.

"The new directive takes discretion out of the hands of tax agents and pushes them to move things along," Ruchelman said.
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