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Secrets of Invalidating Tax Assessments
UNCOVER THE STRATEGIES, TACTICS AND REMEDIES IN INVALIDATING TAX ASSESSMENT
January 18, 2024
2:00pm - 5:00pm
*LIVE VIA ZOOM*
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INTRODUCTION Is your company or business being assessed (or likely to be assessed) by the B.I.R.? Have you received any notice (e.g., Letter of Authority, Subpoena Duces Tecum, Letter Notice, Tax Verification Notice, Notice of Informal Conference, Notice of Discrepancy, Preliminary Tax Assessment, and the like)? Are you prepared? You need to be aware of what exactly you need to do or you will stand to spend an arm and a leg. Uncover the strategies, tactics and remedies in invalidating tax assessment.
COURSE CONTENT
I. Basics of tax assessment
- Legal basis of authority to assess taxpayer
- Prescriptive period of tax assessments
- Three (3) years vs 10 years prescriptive period
- Extension of period to assess through issuance of waiver
- Types of BIR audit/investigation notices
- Letter of authority, Letter Notice, Tax Verification Notice and Mission Order
- Service of assessment notices
- Submission of documents pursuant to BIR notice
- Issuance of subpoena duces tecum
- Application of best evidence rule
II. Stages of tax assessment
- Notice of discrepancy (NOD)
- Preliminary Assessment Notice (PAN)
- Final Assessment Notice (FAN)
- Final Decision Disputed Assessment (FDA)
III. Common audit findings and protesting tax assessment
- Questioning validity of tax assessment at different stages of tax assessment
- Addressing factual and legal issues in tax assessment
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Featured Speaker:
MR. SENEN QUIZON, CPA
Tax Partner - Deloitte Philippines
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- Senen has over 18 years of professional experience in tax services. His experience covers tax ruling assistance, tax investigation assistance, tax training, and tax consultancy for companies engaged in the Manufacturing, Life Sciences & Health Care, and Technology, Media & Telecommunications industries.
- Prior to joining Deloitte, he was the Chief of the Direct Taxes Branch of a government agency, where he conducted numerous studies in the area of direct tax and tax administration. During his stint in the government, he participated in the legislative process by drafting proposed tax legislations and serving as a resource person in public hearings on various tax measures.
- Senen is an Accredited Tax Practitioner of the Bureau of Internal Revenue and is a regular speaker at the Philippine Institute of Certified Public Accountants (PICPA).
- Senen worked for 10 years in another local accounting firm as part of its Tax Knowledge Center, which handles training and publications.
- He earned his degree in Bachelor of Science in Applied Economics from the Polytechnic University of the Philippines and received his Master’s degree in Business Administration from Colegio de San Juan de Letran. He has also attended a variety of foreign tax training programs sponsored by JICA, IMF, and other multilateral agencies.
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