Tax Disputes
When taxpayers disagree with tax authorities about liability or assessments, mediation provides a way to resolve tax disagreements efficiently.
About Tax Disputes
Tax disputes arise when taxpayers disagree with tax authorities about tax liability, assessments, or interpretations of tax law. These may involve questions about deductions, valuations, or the application of tax rules. Such disputes can be complex and involve significant sums. Common situations requiring tax resolution include non-filer status where taxpayers face penalties for failing to file and accumulated liability, outstanding tax debt that exceeds ability to pay, and audit notices for underreported income.
Tax authorities respond to unpaid balances by issuing aggressive collection notices, which precede enforced actions like wage garnishment or bank levies. Tax resolution options include settlement programmes allowing taxpayers to resolve liability for a lesser agreed-upon amount based on their ability to pay, payment plans providing formal paths to pay debt over extended periods, and hardship status that pauses collection activity when payment would create economic hardship.
Mediation offers a constructive way to address tax disputes. The appeals officer assigned to the case attends mediation sessions and retains authority to approve settlements, but the mediator does not impose a decision. If mediation successfully yields a resolution, the agreement is documented in a formal settlement. This approach can resolve disputes efficiently without the cost of lengthy tax litigation while allowing taxpayers to present their case effectively with professional representation.
What is it?
Tax disputes involve conflicts with tax authorities about tax liability, assessments, or interpretations of tax law. This may include disputes about tax returns, assessments, deductions, or the application of tax rules to particular situations. Tax disputes can arise from audits, underreported income, or disagreements about tax treatment of specific transactions.
Your rights and options
When taxpayers disagree with tax authorities about liability or assessments, you have options for resolving the situation. You can negotiate directly, seek mediation to find practical solutions, or pursue formal appeals. Mediation is often the most effective approach because it allows you to present your case effectively while avoiding the costs of litigation.
Mediation provides a confidential space to discuss tax disputes. A neutral mediator helps taxpayers and tax authorities discuss the issues and work towards resolution. This approach can resolve disputes while avoiding litigation costs.
Review tax returns. Think about what outcome would address your needs. The Olive Branch can help resolve tax disputes through mediation.
Frequently Asked Questions
What constitutes a tax dispute?
Tax disputes involve conflicts with tax authorities about tax liability, assessments, or interpretations of tax law. This may include disputes about tax returns, assessments, deductions, or the application of tax rules to particular situations. Tax disputes can arise from audits, underreported income, or disagreements about tax treatment of specific transactions. Common situations include non-filer status, outstanding tax debt, and audit notices.
How are tax disputes resolved?
Tax disputes can be resolved through negotiation with tax authorities, mediation through programmes like the IRS Appeals mediation, formal appeals through the tax authority's appeals process, or litigation in tax court. Tax resolution options include Offer in Compromise (OIC) allowing taxpayers to resolve liability for a lesser amount, Installment Agreements providing formal paths to pay debt over time, and Currently Not Collectible (CNC) status that pauses collection activity when payment would create economic hardship.
Can tax assessments be challenged?
Yes, tax assessments can be challenged through the tax authority's appeals process. Taxpayers have the right to receive notice of assessments and the right to appeal. The appeals process typically involves submitting a written protest explaining why you disagree with the assessment, providing supporting documentation, and potentially participating in a conference with an appeals officer. If the appeal is unsuccessful, taxpayers may further challenge the assessment in tax court.
What happens when taxes are unpaid?
When taxes remain unpaid, tax authorities may take collection actions including issuing aggressive collection notices, imposing liens on property, garnishing wages, levying bank accounts, and seizing assets. The IRS responds to unpaid balances with notices such as CP504 or LT11, which precede enforced actions. Taxpayers facing collection actions should respond promptly and explore resolution options such as installment agreements, offers in compromise, or currently not collectible status to avoid or stop collection actions.
Our Mediation Process
The Initial Consultation
We meet with you to understand your situation, what matters to you, and what justice looks like for you. You tell us your story in your own words, and we explain how mediation could help you achieve it.
Preparation and Contextual Review
We prepare thoroughly so you don't have to. We review the relevant information privately, ensuring we understand the full context before bringing everyone together. You'll know what to expect and can prepare for the conversation ahead.
Setting the Environment
We create a confidential space where you can speak freely and be heard on equal terms. You'll have the opportunity to speak directly to those who need to hear your experience, and we ensure everyone is treated with dignity and respect.
The Facilitated Negotiation
We facilitate a dialogue where you can seek accountability and ask for the change you need to see. You remain in control of the outcome while we help craft solutions that fit your specific circumstances rather than applying a standard approach.
Finalising the Resolution
We conclude with a clear agreement that reflects what matters to you. The resolution is shaped by your needs and gives you a practical path forward, with the understanding that the experience of being heard is as important as the outcome itself.
The Initial Consultation
Your journey begins with a confidential discovery call. You will speak directly with our lead mediator—not an automated system or an intake assistant. During this initial conversation, we will map out the high-level dynamics of your dispute, assess whether mediation is the most strategic path forward for your situation, and answer any immediate procedural questions you may have.
Preparation and Contextual Review
We prepare thoroughly so you don't have to. We review the relevant information privately, ensuring we understand the full context before bringing everyone together. You'll know what to expect and can prepare for the conversation ahead.
Setting the Environment
We create a confidential space where you can speak freely and be heard on equal terms. You'll have the opportunity to speak directly to those who need to hear your experience, and we ensure everyone is treated with dignity and respect.
The Facilitated Negotiation
We facilitate a dialogue where you can seek accountability and ask for the change you need to see. You remain in control of the outcome while we help craft solutions that fit your specific circumstances rather than applying a standard approach.
Finalising the Resolution
We conclude with a clear agreement that reflects what matters to you. The resolution is shaped by your needs and gives you a practical path forward, with the understanding that the experience of being heard is as important as the outcome itself.
Related Specialism
Regulated Sector and Financial Services DisputesSources
International Sources
- OECD Model Tax Convention (Agreement)
- OECD Transfer Pricing Guidelines (Guidelines)
- UN Model Double Taxation Convention (Agreement)
- International Monetary Fund tax policy guidelines (Guidelines)
- World Bank taxation indicators (Indicators)
Continue your search for resolution
Every dispute is personal and complex. We are here to provide the neutral space and expert guidance you need to find a lasting resolution.
Talk to Our Team