Just because a taxpayer missed an election does not mean he or she is completely out of luck. So called “Section 9100 Relief” may provide taxpayers a second chance for certain regulatory elections. This panel reviews the rules for late election relief under Treas. Reg. Sections 301.9100-1 to -3, including how to maximize your chances of obtaining such relief and other ways to fix late elections outside of the Section 9100 process.
Identify procedures and best practices related to filing for Section 9100 relief.
Mary I. Slonina is a Director in PwC’s Tax Controversy and Regulatory Services practice. She assists clients in addressing federal procedural and administrative tax issues and represents clients in interactions with IRS examination and collection functions, the IRS Office of Appeals, and the IRS Office of Chief Counsel.
Practice leader of the Tax Practice and Procedures Group, Ed has over a decade of experience representing individuals, estates, C corporations, Subchapter S corporations and other flow-through entities. He has served on a number of engagements advising on laws applicable to and the policies and procedures followed by the IRS and the various state and local tax jurisdictions in the examination of tax returns, administrative appeals of examination determinations, tax court litigation, and the collection of outstanding tax liabilities.
Prior to joining Mazars, he was an associate in a boutique tax firm, where he participated in the litigation of a variety of federal and state tax controversies.
David is an accomplished author and speaker, and his subject matter expertise is frequently sought out by the media, including the Wall Street Journal and The CPA Journal. In addition to his work at Crowe, David has served on the Internal Revenue Service’s Advisory Council, the senior private sector advisory body to the IRS, and chaired its Small Business and Self-employed Subgroup through 2011. He has also testified before Congress and been featured in the media representing the Certified Public Accountants profession.
Rosemary Sereti is a Managing Director within Deloitte’s Washington National Tax, tax controversy services practice. Prior to joining Deloitte, Ms. Sereti served as the deputy commissioner for the Large Business and International (LB&I) division at the IRS. Rosemary is advising Deloitte Tax LLP’s U.S. clients on navigating IRS examinations and other interactions with the Internal Revenue Service, along with addressing sensitive issues.
In her tenure with the IRS, Rosemary spearheaded notable initiatives while leading a team of more than 5,000 tax professionals and staff. These include designing and implementing the new Compliance Campaign process; forming a cross-functional implementation team to govern and provide strategic oversight for the new partnership audit procedures; and developing a strategic plan to redesign the Compliance Assurance Program and the legacy Coordinated Industry Case Program.
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