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A Case Study in Cutting Edge Audit
Automation (and Notices)
Monday, May 20, 2013 9:45 - 11:00 AM
Presented by: Blake Martin - Vice President,
Head of Tax at Lincoln Financial Group and
Kelley Lear – Managing Director, Red Moon
Solutions
Case Study in
Automation
Financial Services
The Audit Beast Has
Mutated
Cash Hungry Treasury and
States…
 Preparing for and
responding to tax
examinations is growing
more challenging every
day
 More information in
shorter response times
 Global tax authorities are
streamlining their
processes and expanding
resources
Requirements on the Rise
 Federal/state/province
and local tax
enforcement is on the
rise (as is the
sophistication of these
taxing authorities)
 Reporting requirements are expanding: FBAR,
FATCA, transfer pricing disclosures, SOX rules,
global developments around Uncertain Tax
Positions and other tax related contingency
reserves, withholding requirements (B Notices)
and more…
What are your peers saying?
•States are hiring
more auditors.
•All states trying
for reducing audit
aging.
•Voluntary disclosures
are getting pitched more
by the jurisdictions.
•States like NY are getting
more and more automated.
They even have online
service accounts.
•Referrals to state taxing
authorities from other
tax types have ratcheted
up.
•MTC audits can
last forever…
What are your peers saying?
•Getting auditor to
commit to closing audit.
•Extensive, lengthy
audit questionnaires
•Extensive invoice and
sales documentation (e.g.
sales contracts) required by
auditor
•Auditor-prepared monthly
reconciliation of tax return
data vs. workpaper/G/L
data.
•AZ, TX Sales &
Use nightmares
•Stunningly large preliminary
assessments – double what I
expect!!
• I am seeing a lot of
"divergences" from IRM,
procedures, and even taxpayer
rights
Who is Lincoln Financial
Group?
• Provider of life insurance, annuities,
retirement plans, mutual funds and other
financial services
• Fortune 500 company with over 8,000
employees
• Headquartered in the Philadelphia region
– Principal operations also in Indiana and North
Carolina
We consider the “Tax
Function” to be
throughout the company:
• Corporate Tax
Department
• Law Department
• Accounting
• Actuarial
• Business
Operations
What Does our Tax Department
Look Like?
How we are structured:
• Over 30 tax professionals
in 3 locations
• Other stakeholders in
many more locations
• IRS Team located in
Indiana
What Does our Tax Department
Look Like?
What made us take the
leap into automation?
• Why we did we decide to
automate?
– Multi-location tax function with many
parties
– Desire to increase delivery and
resolution time for audit inquiries
– Mail being received in multiple
locations with propmpt replies
required
– Desire to improve controls and
accountability
What was our tipping
point?
• Goal to make all tax
examinations more
collaborative and much faster
• Reduce exposures
• Reduce conflict
• Consider “Continual Audit
Program” (CAP) for federal
audits
Managing the Insanity…
• Federal Income Tax:
– Federal tax examinations, Appeals and Litigation
– Tax and interest re-computations
– Statutes of Limitations and extensions
• State Income Tax:
– Delinquency notices (unfiled returns) & notices of
assessment
– Tax payer requests for change of tax information
– Notice of adjustment to corporate income
– Notice of late filing
• Premium Tax (State and Muni):
– Notice of Class B Assessments
– Underpayment and Overpayments
– Tax payment process and tracking
– Special Assessments and delinquency
– Incorrect withholding
• Sales & Use Tax:
– Letters of Inquiry with respect to a jurisdiction
(corporate business tax, state business tax and
seller’s use tax)
– Underpayment and Overpayments
• Information Reporting
– 1099’s, B Notices, Other..
Managing the Insanity…
• Federal W/H, FICA, FUTA, SUTA:
– Overpayments and underpayments (interest and penalties)
– Unemployment Insurance
• State W/H:
– Notice of W/H tax due
– Tax payment confirmation and tracking
– Refunds requested
• Personal Property Tax:
– Demand for Personal Property Tax Payment
– Payment documentation and tracking
– Assessment and invoices
• Real Property Tax:
– Returns
– Payments
– Assessments and invoices
– Payment documentation and tracking
• Guarantee Fund Assessments
• State & Local Business Licenses
People, Process and
Technology to the Rescue
• Goals
• Accountability
• Control
• Transparency
• Designed an overall process
• Identified entry points (mail, tax authorities,
etc.)
• Identified actions required
• Identified roles and responsibilities
• Provides online control and visibility for
every tax type, notices, full
audit cycle and results!
• Full end to end automation and tracking of all notices
• Utilizing eTaxPortal – NoticeTracker
• Can link to audit projects as well
• Full end to end automation and
tracking of audit inception through
payment, protest and appeals
(as applicable):
 IDR
 RAR
 NOPA or NPA
 6662
 Tax Claim
 Protest & Appeals
People, Process and
Technology to the Rescue
Log and
respond to
IDR’s
Automate
back and
forth
responses
Respond to
RAR’s
Automate
responses
to NOPA’s
and
tracking
Finalize,
and/or pay,
protest or
appeal
IRS Audit
Notices
Notices Rec’d
in GSO Mail
Notices Received
in Mail
Enter into Notice
Log (date stamped)
Attach Scanned
Copy of Notice
Automatically
Assigned to Leader
Notice Automation
Leader Reviews and Assigns to
Staff (system date stamp)
Staff Prepares Resources
Staff Reviews and Responds
(system date stamped)
Attach Copy of Correspondence
Sent to Taxing Authority (system
date stamped)
Audit Automation
Attach Response if Final Notice
and Mark “Closed”
Request for Addit’l Info / Staff
Reviews and Responds (system
date stamped)
Attach Final Notice Indicating
Closed and Mark “Closed”
Attach Copy of Correspondence
Sent to Taxing Authority (system
date stamped)
Audit Automation
Now What Does the Process
Look Like in the eTaxPortal?
Notice Types are set up
already and have default
routing to “Assign To Leader”
012
What are we learning
through this process?
• Process has to be designed for
your organization
– Identify population to be managed
– Communicate initial process and
roles
– Be prepared to change the design
quickly
• There are many small issues you won’t
initially identify that will seem to
continually pop up
What are we learning
through this process?
– Design a change
process to maintain
controls
• Emphasize that this is the
new (and only) process
• Slow reaction to
problems will build
disillusion and resistance
– Review frequently with
Red Moon
– Plan for the future
Step 1
Step 2
Step 3
Review
What are we learning
through this process?
Results:
• Better relations with tax
authorities
• More accountability
• Single control, no more
individual spreadsheet
controls
• Fewer errors
• Reduced interest and
penalties
What are we looking
forward to further
automating?
Next Steps:
• Tax Projects
• Tax Developments
• Tax Records Management
• Governance of Tax Processes
• Use of Tax Calendar
Thank you for reading!
For more information, contact me at:
Kelley Lear
Kelley.Lear@redmoonsolutions.com
941-379-7108
Blake Martin
Blake.martin@lfg.com
484-583-1471
www.redmoonsolutions.com
blog.redmoonsolutions.com
www.twitter.com/redmoonsolution

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A case study in cutting edge audit automation (2)

  • 1. A Case Study in Cutting Edge Audit Automation (and Notices) Monday, May 20, 2013 9:45 - 11:00 AM
  • 2. Presented by: Blake Martin - Vice President, Head of Tax at Lincoln Financial Group and Kelley Lear – Managing Director, Red Moon Solutions Case Study in Automation Financial Services
  • 3. The Audit Beast Has Mutated
  • 4. Cash Hungry Treasury and States…  Preparing for and responding to tax examinations is growing more challenging every day  More information in shorter response times  Global tax authorities are streamlining their processes and expanding resources
  • 5. Requirements on the Rise  Federal/state/province and local tax enforcement is on the rise (as is the sophistication of these taxing authorities)  Reporting requirements are expanding: FBAR, FATCA, transfer pricing disclosures, SOX rules, global developments around Uncertain Tax Positions and other tax related contingency reserves, withholding requirements (B Notices) and more…
  • 6. What are your peers saying? •States are hiring more auditors. •All states trying for reducing audit aging. •Voluntary disclosures are getting pitched more by the jurisdictions. •States like NY are getting more and more automated. They even have online service accounts. •Referrals to state taxing authorities from other tax types have ratcheted up. •MTC audits can last forever…
  • 7. What are your peers saying? •Getting auditor to commit to closing audit. •Extensive, lengthy audit questionnaires •Extensive invoice and sales documentation (e.g. sales contracts) required by auditor •Auditor-prepared monthly reconciliation of tax return data vs. workpaper/G/L data. •AZ, TX Sales & Use nightmares •Stunningly large preliminary assessments – double what I expect!! • I am seeing a lot of "divergences" from IRM, procedures, and even taxpayer rights
  • 8. Who is Lincoln Financial Group? • Provider of life insurance, annuities, retirement plans, mutual funds and other financial services • Fortune 500 company with over 8,000 employees • Headquartered in the Philadelphia region – Principal operations also in Indiana and North Carolina
  • 9. We consider the “Tax Function” to be throughout the company: • Corporate Tax Department • Law Department • Accounting • Actuarial • Business Operations What Does our Tax Department Look Like?
  • 10. How we are structured: • Over 30 tax professionals in 3 locations • Other stakeholders in many more locations • IRS Team located in Indiana What Does our Tax Department Look Like?
  • 11. What made us take the leap into automation? • Why we did we decide to automate? – Multi-location tax function with many parties – Desire to increase delivery and resolution time for audit inquiries – Mail being received in multiple locations with propmpt replies required – Desire to improve controls and accountability
  • 12. What was our tipping point? • Goal to make all tax examinations more collaborative and much faster • Reduce exposures • Reduce conflict • Consider “Continual Audit Program” (CAP) for federal audits
  • 13. Managing the Insanity… • Federal Income Tax: – Federal tax examinations, Appeals and Litigation – Tax and interest re-computations – Statutes of Limitations and extensions • State Income Tax: – Delinquency notices (unfiled returns) & notices of assessment – Tax payer requests for change of tax information – Notice of adjustment to corporate income – Notice of late filing • Premium Tax (State and Muni): – Notice of Class B Assessments – Underpayment and Overpayments – Tax payment process and tracking – Special Assessments and delinquency – Incorrect withholding • Sales & Use Tax: – Letters of Inquiry with respect to a jurisdiction (corporate business tax, state business tax and seller’s use tax) – Underpayment and Overpayments • Information Reporting – 1099’s, B Notices, Other..
  • 14. Managing the Insanity… • Federal W/H, FICA, FUTA, SUTA: – Overpayments and underpayments (interest and penalties) – Unemployment Insurance • State W/H: – Notice of W/H tax due – Tax payment confirmation and tracking – Refunds requested • Personal Property Tax: – Demand for Personal Property Tax Payment – Payment documentation and tracking – Assessment and invoices • Real Property Tax: – Returns – Payments – Assessments and invoices – Payment documentation and tracking • Guarantee Fund Assessments • State & Local Business Licenses
  • 15. People, Process and Technology to the Rescue • Goals • Accountability • Control • Transparency • Designed an overall process • Identified entry points (mail, tax authorities, etc.) • Identified actions required • Identified roles and responsibilities • Provides online control and visibility for every tax type, notices, full audit cycle and results!
  • 16. • Full end to end automation and tracking of all notices • Utilizing eTaxPortal – NoticeTracker • Can link to audit projects as well • Full end to end automation and tracking of audit inception through payment, protest and appeals (as applicable):  IDR  RAR  NOPA or NPA  6662  Tax Claim  Protest & Appeals People, Process and Technology to the Rescue Log and respond to IDR’s Automate back and forth responses Respond to RAR’s Automate responses to NOPA’s and tracking Finalize, and/or pay, protest or appeal
  • 17. IRS Audit Notices Notices Rec’d in GSO Mail Notices Received in Mail Enter into Notice Log (date stamped) Attach Scanned Copy of Notice Automatically Assigned to Leader Notice Automation
  • 18. Leader Reviews and Assigns to Staff (system date stamp) Staff Prepares Resources Staff Reviews and Responds (system date stamped) Attach Copy of Correspondence Sent to Taxing Authority (system date stamped) Audit Automation
  • 19. Attach Response if Final Notice and Mark “Closed” Request for Addit’l Info / Staff Reviews and Responds (system date stamped) Attach Final Notice Indicating Closed and Mark “Closed” Attach Copy of Correspondence Sent to Taxing Authority (system date stamped) Audit Automation
  • 20. Now What Does the Process Look Like in the eTaxPortal? Notice Types are set up already and have default routing to “Assign To Leader”
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  • 32. What are we learning through this process? • Process has to be designed for your organization – Identify population to be managed – Communicate initial process and roles – Be prepared to change the design quickly • There are many small issues you won’t initially identify that will seem to continually pop up
  • 33. What are we learning through this process? – Design a change process to maintain controls • Emphasize that this is the new (and only) process • Slow reaction to problems will build disillusion and resistance – Review frequently with Red Moon – Plan for the future Step 1 Step 2 Step 3 Review
  • 34. What are we learning through this process? Results: • Better relations with tax authorities • More accountability • Single control, no more individual spreadsheet controls • Fewer errors • Reduced interest and penalties
  • 35. What are we looking forward to further automating? Next Steps: • Tax Projects • Tax Developments • Tax Records Management • Governance of Tax Processes • Use of Tax Calendar
  • 36. Thank you for reading! For more information, contact me at: Kelley Lear Kelley.Lear@redmoonsolutions.com 941-379-7108 Blake Martin Blake.martin@lfg.com 484-583-1471 www.redmoonsolutions.com blog.redmoonsolutions.com www.twitter.com/redmoonsolution

Editor's Notes

  1. Kelley: As we all know, federal coffers are in dire need of tax revenue. And with federal funding for states all but dried up, the audit beast we have been talking about for the past year, is mutating into a whole new beast. That beast has a suit and tie, but has a hunger that just can’t be quenched. And in some cases, doesn’t seem to be playing fair!
  2. Kelley: In fact, I ran across a survey recently given by Ernst & Young, LLP (EY), which is their Tax Risk and Controversy Survey which examines the fact that the greater uncertainty out there is posing new financial and reputational risk for leaders of global companies. The survey expounds further by sharing that 77% of respondents in their 541-company survey said managing tax risk and controversy will become even more important to them in the next two years, and this figure increases to 88% for large companies. Yikes.
  3. Kelley: As you already know I’m sure, tax enforcement is on the rise (as is the sophistication of these taxing authorities) – and in some cases however we are hearing the direct opposite which includes a lack of skilled and /or sophisticated examiners or agents as they are scaling up so quickly that skillsets are not a priority. In addition, phasing in last year and even heavier this year, more reporting requirements than ever before. FBAR, FATCA and other withholding requirements and documentation. It should prove to continue to be a challenging environment.
  4. Kelley: Given these global challenges, I thought I would also share what some of your peers are saying out there. I often converse and ask questions out there through social media and on LinkedIn and this is what folks have been saying…these are focused on states.Illinois hired 50 new auditors by the beginning of December. So, further proof of ‘ramping up”.As far as sophistication…NY- created what the taxing authorities are calling an “new sophisticated” transparent audit selection process that is almost wholly computer driven, in a hope to uncover fraud and underpaying taxpayers more easily. Even the IDR process will be automated.State transfer pricing – some states are hiring transfer pricing consultants to review state corporate tax return data to identify taxpayers with “thin transfer pricing” based on narrow profit margins or continuing losses. This is a great quote on MTC audits…”I think the one thing I am most concerned about with audits is getting a call from the MTC.  Their audits consume vast quantities of time, resource, and paper, only to be delivered results that are significantly wrong.  The one size fits all doesn't work for any state and neither do their sloppy audits.  They will do 8 to 12 states at a time.  They do both state income tax and sales / use tax audits together.  Unfortunately their auditors do not seem to know the individual state laws and will apply what they think the law should be across the board to all the states under audit.
  5. Kelley: A stunningly large preliminary assessment. The assessment was almost $1 Million! To put this into perspective, such an assessment, if any, should have been approx. $50,000! at most.. Another several tax pros said that Tennesse had it’s sales/use challenges - Getting auditors to commit to closing the audit is really challenging. An auditor sent annual waivers 3 times in the past 3 years rather than close out a relatively nominal $30,000 audit.Lengthy audit questionnaire. Easily the most extensive listing of questions that I had ever seen from an auditor. At 1 point I asked the auditor if he was going to apply for a job with us!Arizona and Texas are the worst right now for sales/use issues. There are an extensive volume of invoices required for auditor sampling + resolving auditor-prepared monthly reconciliation of tax return data vs. work paper/G/L data. I am seeing lots of “divergences” from IRM, procedures and even tax payer rights in some cases!--
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  9. Blake – any help from Kelley?
  10. Blake – any help from Kelley?
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