Speaker 1: My name is Sharon Katz-Perlman, I lead the firm's Tax Dispute Resolution Network and I also lead the global firm's Tax Dispute Resolution Group for KPMG International. Prior to joining the firm, which is many years ago already, I was a litigator with the Treasury Department and so my practice now focuses on representing clients before the Internal Revenue Service and providing assistance in disputes. When dealing with a dispute today, companies really have to be prepared for a number of things. The landscape in the United States has changed and is still changing. We are seeing the IRS go to a much more risk-based analysis. When they look at companies, they're leaving the broad-based, we'll come in and examine everything and really trying to focus on specific issues where they think that they're going to be able to generate revenue. So I think there's a need to be prepared for a focused exam on critical issues. You need to be prepared for the fact that your information is much more likely to be shared with other jurisdictions. The collaboration cross-border now is at really an all-time high. There are lots of things happening. Think about BEPS. Think about cross-border information sharing we spoke about during the program this morning. But that is causing a shift and so if you enter a process of dispute resolution knowing that your information is going to be shared, there's really a need to think about consistency and making sure that the information is all correct globally and you can't just be focused on one particular jurisdiction anymore. Also specific to the U.S., there is an increased focus here on information gathering. So during the course of your audit, the IRS is now focused on developing the issues better and asking very specific questions and they expect responses in a very timely fashion now. And if you don't provide those responses, there's a much greater likelihood that this is going to escalate and that there's going to be summons involvement and things can get a lot more difficult. The last thing that I think companies should be aware of is that there is a very large focus now on partnership exams. For many years, the service has been saying we're going to look at partnerships, we're going to focus on partnerships, and they didn't. And they were dinged for it, if you will. They were told that they had missed the boat, that they'd missed a lot of potential revenue. So now we are starting to see that there's absolutely a climb in the number of audits of partnerships of all sizes. So I think that's something to be prepared for as well. I think that's something to be prepared for as well. I think that's something to be prepared for as well. I think that's something to be prepared for as well.