Washington National Tax – Practice, Procedure and Administration 

The Practice, Procedure and Administration group in KPMG LLP’s Washington National Tax practice is responsible for technical analysis, issue development and advice on all matters related to federal tax practice, procedure and administration.

Our services cover, but are not limited to:

IRS Dispute Resolution
  • Representing you in traditional IRS examinations or appeals, and through special case/issue resolution procedures, such as Pre-Filing Agreements (PFAs), the Compliance Assurance Program (CAP), Limited Issue Focus Examinations (LIFE), Fast Track Appeals, and Industry Issue Resolutions (IIRs)

    Tax Returns and Refund Claims

  • Providing advice and assistance with tax return filing requirements, return disclosures, reportable transactions, professional standards and statutes of limitation, as well as assistance with the filing of amended tax returns, including qualified amended returns, claims for refund, applications for tentative refund of tax, Joint Committee on Taxation review of large refund claims and tentative refunds, and correction of errors

    IRS Rulings

  • Obtaining rulings from the IRS National Office in such areas as “9100 relief” for late check-the-box and other elections, and reasonable cause and other relief from failure to timely enter into gain recognition agreements, inadvertent termination of S corporation status and failure to timely comply with FIRPTA, PFIC and other reporting provisions

    Penalties and Relief

  • Helping you understand penalty standards and pursue opportunities for relief, including penalties for late filing of tax returns or payment of tax, accuracy-related penalties, penalties for nondisclosure of reportable transactions, penalties for transactions lacking economic substance or business purpose and penalties for failure to comply with foreign information reporting and other requirements

    Information Reporting and Withholding

  • Providing advice and assistance on federal tax reporting and withholding issues, including payments reportable on Forms 1099, Form 1042-S and Form W-2; the reporting of foreign financial accounts (FBAR reporting requirements); and the new withholding regime aimed at expanding reporting of U.S. persons investing offshore (FATCA withholding and reporting requirements)


Paul Manning, Principal-in-Charge