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BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms.
BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms.
BDO KNOWLEDGE Tax Webinar Series Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest Todd Simmens, National Managing Partner of Tax Risk Management, BDO USA, LLP Cathy Stopyra, Managing Director, Account and Interest Recovery Services, BDO USA, LLP April 24, 2014
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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CPE and Support CPE Participation Requirements ‒ To receive CPE credit for this webcast:
You’ll need to actively participate throughout the program. Be responsive to at least 75% of the participation pop-ups.
Certificate of Attendance: If you are logged in the entire time and respond to all participation pop-ups, you will be able to print your certificate from the “Participation” section at the end of the webcast. If you log out before printing your certificate:
BDO USA professionals ‒ CPE will automatically be issued in CPE Tracking & Reporting at the end of every week. A copy of your certificate will be sent after you have been issued credit.
All others will be emailed instructions on how to access your certificate.
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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CPE and Support (cont’d) Group Participation ‒ To receive credit:
Sign-in sheets must list a Proctor name and CPA license number. BDO USA professionals ‒ Submit your sign-in sheets using a General Training & Development Request
in BDO Service Now found at: BDOWorld > Applications & Resources > BDO Service Now > Click “Service Catalog” in the left menu, then under Training & Development, “Make a Request”.
Clients and contacts ‒ Email sign-in sheets to [email protected] within 24 hours of the webcast. Alliance members ‒ Should proctor their own group participants. This process is detailed in the
LearnLive Participant Guide, which can be found by searching “LearnLive Participant Guide” on the Alliance Portal. Call LearnLive Support below for questions.
Unfortunately, we cannot currently support group CPE for International Firms. Those wanting CPE must register and log in on their own computer.
Q&A: Submit all questions using the Q&A feature on the lower right corner of the screen. At the end of the presentation, the presenter(s) will review and answer all questions submitted. Technical Support: If you should have technical issues, please contact LearnLive:
Click on the Live Chat icon under the Support tab, OR Call: 1-888-228-4088
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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With You Today
Todd Simmens National Managing Partner of Tax Risk Management BDO USA, LLP 90 Woodbridge Center Dr. 4th Floor Woodbridge, NJ 07095 (732) 491-4170, [email protected]
Cathy Stopyra Managing Director, IRS Accounts and Interest — Specialized Tax Services BDO USA, LLP 90 Woodbridge Center Dr. 4th Floor Woodbridge, NJ 07095 (732) 734-1009 [email protected]
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Objectives
Recognize the statutory requirements regarding deficiency interest
Understand the role of IRS Account Processing
Understand BDO’s Account and Interest Recovery Service (AIRSSM)
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Agenda
Payment requirements
Penalties
Interest
Refunds
IRS accounts
BDO’s AIRS offering
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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PAYMENTS
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Estimated Tax Payments
Section 6655 imposes addition to tax when a corporation (C or S) makes underpayment of estimated tax
Corporation must make estimated payments if tax shown on return (income minus credits) is $500 or more
Penalty rate equals the §6621 underpayment interest rate
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Estimated Tax Payments - Corporations
Corporations make quarterly payments
Each installment is 25 percent of required annual payment, which is the lesser of:
100 percent of tax shown on return for taxable year
100 percent of tax shown on corporation’s return for preceding taxable year
Amount determined under the annualized method
Amount determined under the adjusted seasonal method
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Estimated Tax Payments - Individuals
Individuals/estates/trusts must pay four minimum income tax installment payments throughout the year
Each installment is 25 percent of required annual payment, which is the lesser of:
90 percent of tax shown on return for taxable year
100 percent of tax shown on individual’s return for preceding tax year
If adjusted gross income exceeds $150,000, percentage is 110 percent (historically a favorite revenue raiser)
Failure to make payment subjects taxpayer to same addition to tax as corporations under §6655
April 15, June 15, September 15, January 15 (next year)
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Electronic Federal Tax Payment System (EFTPS) Free tax payment system provided by Department of Treasury
Businesses and individuals can pay all their federal taxes using EFTPS
Secure government Web site
Fast, accurate, and convenient
All deposits must be made electronically
www.eftps.gov
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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PENALTIES
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Purpose of Federal Tax Penalties (or Additions to Tax) I.R.M. 20.1.1.2 (02-22-2008), Purpose of Penalties.
Penalties exist to encourage voluntary compliance by supporting the standards of behavior expected by the Internal Revenue Code.
For most taxpayers, voluntary compliance consists of preparing an accurate return, filing it timely, and paying any tax due. Most penalties apply to behavior that fails to meet any or all of these obligations.
Penalties encourage voluntary compliance by:
Defining standards of compliant behavior
Defining remedial consequences for noncompliance
Providing monetary sanctions against taxpayers who do not meet the standard
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Failure-to-File and Failure-to-Pay Penalties
Failure to File Tax Return (IRC §6651(a)(1))
Five percent of the amount required to be shown on return as tax per month, with a 25 percent maximum
25 percent maximum interacts with §6651(a)(2)
Reasonable cause exception
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Failure-to-File and Failure-to-Pay Penalties (continued) Failure to Pay (IRC §6651(a)(2))
0.5 percent of tax shown on return per month with 25 percent maximum penalty if tax not paid by the due date (without regard to extension) of that return
25 percent maximum interacts with §6651(a)(1)
Can be increased to 1%
Applies to:
Income, employment, excise, gift, and estate tax returns
Reasonable cause exception
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Estimated Tax Penalty
IRC §6654 and §6655
Installments based on pay-as-you-go system
Failure to timely pay installment will result in penalty
Amount based on number of days the installment is late, times the interest rate in effect
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Other Federal Tax Penalties
Other penalties apply for failure to file certain returns or make payments:
Information returns (See IRC §§6721 and 6722)
Reasonable cause
Payments of estimated tax (See IRC §6655 below)
No reasonable cause
Partnership returns (See IRC §6698)
Reasonable cause
Accuracy-Related (See IRC §6662)
Reasonable cause
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INTEREST
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Interest
What is interest?
Not a tax
Not a penalty
How is it assessed?
Code sections dealing with interest
Section 6601: Underpayments
Section 6611: Overpayments
Section 6621: Rates
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Interest (continued)
Interest is due on underpayments from the last date prescribed for payment of a tax until the date such amounts are paid
Deficiency interest is charged only when a liability is both due and unpaid
Avon Products Inc. v. U.S.; May Department Stores v. U.S.; Sequa Corp. v. U.S.
Rev. Rul. 88-98; Rev. Rul. 99-40
IRC §905(c)
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Overpayment Interest
Generally, interest is allowed on overpayments from the date the overpayment arises to the date such amount is refunded or credited
Allowable interest is subject to the 45-day rule, whereby the government has 45 days to process a return before incurring allowable interest. Applicable to:
Original return filed reflecting overpayment
Amended return reflecting overpayment
Carryback claims
IRS-initiated adjustment
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Interest Rates as for Q2 of 2014* (rates change quarterly) Three (3) percent for overpayments [two (2) percent in the case of a corporation];
Three (3) percent for underpayments;
Five (5) percent for large corporate underpayments; and
One-half (0.5) percent for the portion of a corporate overpayment exceeding $10,000
In Q2 of 2007…
Underpayments – eight percent
Large corporate underpayments – 10 percent
Overpayments – eight percent
Corporate overpayments – eight percent
• Five and a half percent for portion of corporate overpayment exceeding $10,000
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Limitations Period on Interest
Taxpayer has six years from allowance of a refund to receive correct amount of overpayment interest
If not received prior to expiration of six years, suit must be filed to protect right to such refund
Statute of limitations for requesting a refund of overpaid underpayment interest is the same as for requesting refund of overpaid tax
Generally, three years from date the return is filed or two years from date interest was paid
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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“Hot” Interest
IRC §6621(c) provides for an increased interest rate charged on certain large corporate underpayments in excess of $100,000
Trigger date:
A balance due notice for more than $100,000 tax due may create trigger date
Issuance of a 30-day or 90-day letter for greater than $100,000 in tax may set a trigger date
Trigger date not set if amount shown as due is paid within 30 days of issuance of notice or letter
Trigger date often times incorrect on account transcript
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Advanced Payments and Deposits To stop the running of interest
Advance Payments Deposits (per IRC §6603 and Rev. Proc. 2005-18)
Is the remittance considered a payment of tax on the date it is received by the IRS?
Yes No
Does the remittance stop deficiency interest on portion of deficiency equal to the deposit the date it is received by the IRS?
Yes Yes
Will the remittance, depending on amount, prevent the setting of the “hot interest” trigger date for corporate taxpayers under IRC §6621(c)?
Yes No
Will the remittance prevent taxpayer from going to Tax Court?
May prevent taxpayer from going to Tax Court if deficiency is fully satisfied
Will not prevent taxpayer from going to Tax Court
When is deficiency interest deductible (assuming such interest is deductible)?
Interest included in advance payment may be specifically identified and deducted when paid
Deficiency interest included in deposit is not deducted until applied as payment of tax
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Advanced Payments and Deposits (continued) To stop the running of interest
Advance Payments Deposits (per IRC §6603 and Rev. Proc. 2005-18)
When does the statute of limitations on amount under IRC §6511 begin?
Generally begins on date payment is received
Begins on date deposit is converted to a payment
Can taxpayer request that the remittance be returned?
No. Refund not made until overpayment determined. May have to file claim for refund.
Yes, at any time prior to it being used as a payment of tax or the IRS determines that collection of tax is in jeopardy
If remittance returned to payer, is allowable interest payable?
Yes (federal short term plus 3% points, or 2% points for corps., or 0.5% for corp. refunds over $10,000)
Yes (but only at the federal short-term rate, and only if it is attributed to a “disputable tax”)
Can remittance be returned to taxpayer if assessment is determined to be barred or invalid?
Not if paid prior to the expiration of the statute of limitations on assessment
Probably
Can returned remittance be used in interest netting under IRC §6621(d)?
Yes No, not prior to date it is converted to a payment
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Restricted Interest
Interest computed where start and/or stop dates are other than due date of return to payment/refund date
In general, term applies in situations where interest might be statutorily prohibited or limited to specific time frames:
45-day rule on overpayments
Signing of Form 870 or 870AD
Carrybacks/Recaptures
Processibility
General adjustment combination
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Interest Netting
IRC 6621(d)
The application of a zero-rate of interest to the extent that there are overlapping tax underpayments and overpayments; different tax modules
Interest rate differential for corporations ranging from one to four and a half percent
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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REFUNDS AND OVERPAYMENTS
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What is an Overpayment?
No refund until there is an overpayment
No definition in Internal Revenue Code
Section 6401 gives some examples, including:
Tax assessed or collected after the expiration of the statute of limitations
Supreme Court gave definition:
Any payment of tax in excess of the amount that is rightfully due
Remember, though, that not all remittances are payments
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Requirement for Valid Claim
IRS does not have authority to release an overpayment until the taxpayer files a claim for refund (except in cases of math errors)
Taxpayer must submit:
Identifying information (i.e., year, taxpayer, explanation)
Grounds on which the refund is claimed
Most important
Computation of refund not necessary
On a timely basis
Signed
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Types of Claims
There are three general types of refund claims:
Formal claims
Informal claims
Protective claims
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Limitations Period on Filing Interest and Penalty Claims If return was filed, claim must be filed within three years from date return was
filed or two years from date tax was paid, whichever is later
If return was not filed, claim must be filed within two years from date tax was paid
If taxpayer agreed to extend statute of limitations on assessment of tax, claim may be filed at any time during the extended period provided in the agreement, plus an additional six months
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IRS ACCOUNT PROCESSING
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IRS Calendar Date v. Cycle
All accounts have IRS codes specific to each transaction
The calendar posting date may not be the date for interest or penalty computations
Account transactions are posted in weekly cycles
Account transactions are subject to IRS quality review
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BDO’S ACCOUNT AND INTEREST RECOVERY SERVICES – AIRSSM
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BDO’s Account and Interest Recovery Services – AIRSSM
A highly valued, specialized service for all clients in which we complete a comprehensive review of their IRS accounts. The sophistication of our analysis allows us to determine if the corporation or individual is entitled to any refund of penalties or interest in connection with its federal taxes. Our analysts have the in-depth knowledge and expertise necessary to make such determinations.
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BDO’s Account and Interest Recovery Services – AIRSSM
(continued) Contingency-based fee
Findings-based
Tiered
Phased
SEC BDO Attest
Flat fee
Time and expense
Phase determination
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BDO’s Account and Interest Recovery Services – AIRSSM
(continued) Who benefits from an AIRS project?
…Sold, liquidated, or acquired an entity?
…Filed a carryback?
…Had an IRS audit?
…Had an overpayment on an original return?
…Filed an amended return?
…Owed tax in one period, but had an overpayment in another?
…Received any IRS refunds?
…Paid any IRS penalties?
…Had an offset between accounts?
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BDO’s Account and Interest Recovery Services – AIRSSM
(continued) Notes to remember…
Best practices
No red flags
No revocation of prior POAs
IRS account transcripts
Specialized software
Claims
Referral on out of scope issues
Minimum client time involvement
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BDO’s Account and Interest Recovery Services – AIRSSM
(continued) Successes…
Client completed IRS examination; Rev. Rul. 99-40
Individual client; section 6404(g)
Client with assessed FTD penalty; section 6656
Client with processibility issue; section 6611(g)
Client issued refund without interest; section 6611(e)
Client with a credit offset; section 6402
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AIRSSM RETURN ACCOUNTS ANALYZED
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Types of Federal Returns
Income tax
Excise tax
Employment tax
Gift tax
Estate tax
Information returns
Other federal returns
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Most Common Return Forms
Form 1120 – Corporations
Form 1065 – Partnerships
Form 1120-S – S corporations
Form 1040 – Individuals
Form 1041 – Income of trusts and estates
Form 720 – Excise tax
Form 706 – Estate tax
Form 709 – Gift tax
Form 940, 941, 944, 945 – Employment tax
Form 990 – Organization exempt from tax (return)
Forms 5471, 8865, 8858, 5472 – International information returns
Form 1042 - Withholding
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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CONCLUSION
BDO KNOWLEDGE Tax Webinar Series ‒ Don’t Leave Cash on the Table: Recovering Your Overpaid Interest and Underpaid Refund Interest
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Objectives
You should now have a better understanding of:
Recognizing the statutory requirements regarding deficiency interest
The role of IRS Account Processing
BDO’s Account and Interest Recovery Service (AIRSSM)
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Contacts
Greg Martinelli Senior Director, Tax Controversy and Procedure BDO USA, LLP 1700 Market Street 29th Floor Philadelphia, PA 19103 (215) 636-5519 [email protected]
Cathy Stopyra Managing Director, IRS Accounts and Interest — Specialized Tax Services BDO USA, LLP 90 Woodbridge Center Dr. 4th Floor Woodbridge, NJ 07095 (732) 734-1009 [email protected]
Todd Simmens National Managing Partner of Tax Risk Management BDO USA, LLP 90 Woodbridge Center Dr. 4th Floor Woodbridge, NJ 07095 (732) 491-4170, [email protected]
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xxx
xxx
xxx
• xxx
Questions
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Conclusion Thank you for your participation!
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SPEAKER BIOGRAPHIES
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Biography Todd Simmens
Todd Simmens National Managing Partner of Tax Risk Management BDO USA, LLP 90 Woodbridge Center Dr. 4th Floor Woodbridge, NJ 07095 (732) 491-4170, [email protected]
Todd Simmens is BDO’s National Managing Partner of Tax Risk Management. Todd is responsible for managing tax risk issues for the firm, including tax return preparer issues, client-related practice issues, reportable transaction consulting, and overseeing the tax practice’s Tax Controversy & Procedure practice. Todd served as BDO’s Managing Partner of Tax Controversy & Procedure prior to assuming his current role.
Prior to joining BDO, Todd was a member of the Tax Controversy & Risk Management Services practice of Ernst & Young, LLP. He also practiced law at White & Case LLP, where he assisted in the writing and production of Michael I. Saltzman’s IRS Practice and Procedure (Revised Second Edition).
Additionally, Todd served as legislation counsel to the U.S. Congress Joint Committee on Taxation, where his duties included coordinating issues involving the 2001 repeal of the estate, gift, and generation-skipping transfer taxes, as an associate with Blank Rome LLP, and as law clerk to U.S. Tax Court Judge Joel Gerber.
Todd is the co-author of Tax Management Portfolio (BNA) No.648, Reportable Transactions.
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Biography Cathy Stopyra
Cathy Stopyra Managing Director, IRS Accounts and Interest — Specialized Tax Services BDO USA, LLP 90 Woodbridge Center Dr. 4th Floor Woodbridge, NJ 07095 (732) 734-1009 [email protected]
Cathy has extensive public accounting and IRS experience and currently analyzes clients’ IRS tax accounts, addresses various client inquiries, and resolves related problems and concerns. She is knowledgeable in the following areas: account analysis, review of IRS tax examination reports, payment application, interpretation and resolution of IRS notices, interest computation, and penalty administration.
Prior to BDO, Cathy served as a member of the accounts and interest group within tax controversy and risk management services at Ernst & Young. She also worked in several capacities while at the IRS, including positions as tax auditor, problem resolution caseworker, internal revenue agent, employment tax specialist, and senior reviewer in quality measurement staff. She coordinated the interest program and implemented required area procedures for examination staff. As the restricted interest coordinator, Cathy gained a thorough understanding of account analyses and the application of the interest provisions of the Internal Revenue Code.
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BDO is the brand name for BDO USA, LLP, a U.S. professional services firm providing assurance, tax, financial advisory and consulting services to a wide range of publicly traded and privately held companies. For more than 100 years, BDO has provided quality service through the active involvement of experienced and committed professionals. The firm serves clients through 49 offices and more than 400 independent alliance firm locations nationwide. As an independent Member Firm of BDO International Limited, BDO serves multinational clients through a global network of 1,264 offices in 144 countries. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. BDO is the brand name for the BDO network and for each of the BDO Member Firms. www.bdo.com To ensure compliance with Treasury Department regulations, we wish to inform you that any tax advice that may be contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or applicable state or local tax or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. Material discussed in this publication is meant to provide general information and should not be acted on without professional advice tailored to your individual needs. © 2014 BDO USA, LLP. All rights reserved. www.bdo.com