01
An IRS payroll tax audit is underway
Forms 941, W-2, 1099, payroll registers, and the general ledger do not tell the same story—or the IRS has requested records.
Audit and dispute support →Federal IRS Controversy · Compensation · Employment Tax
When compensation issues become IRS controversy.
GWD helps employers and professional advisors evaluate and respond to federal tax issues involving executive compensation, employee benefits, and employment tax.
Former IRS Senior Revenue Agent and GS-14 Compensation & Benefits Subject Matter Expert experience.
Recognize the trigger
When these issues surface, the tax exposure can move quickly.
A notice, audit request, transaction, employee complaint, or year-end reconciliation can expose compensation and payroll tax issues that cross records, tax years, and responsible teams. Select a concern to see how GWD can support the review or controversy response.
02
Owner distributions exceed reported wages
An S corporation owner performs substantial services, but compensation records, distributions, and business activity may not align.
S corporation controversy →03
Workers were treated as contractors
Contracts, actual work practices, payroll, and information returns may point in different directions, creating employment tax exposure.
Classification review and controversy →04
Payroll deposits or withheld taxes are unpaid
Deposit penalties, collection action, and potential Trust Fund Recovery Penalty questions can make timing and records critical.
Payroll tax collection matters →05
Executive or equity pay created an IRS issue
Deferred compensation, equity awards, severance, change-in-control payments, or executive deductions are being questioned.
Executive compensation controversy →06
Benefits may be missing from Forms W-2
Perquisites, expense reimbursements, fringe benefits, or equity events may not reconcile to payroll, tax returns, and source documents.
Benefits and reporting review →07
An ACA or information-reporting notice arrived
Employee-month data, coverage offers, payroll hours, and Form 1095-C codes may be inconsistent or incomplete.
ACA notice and reporting support →08
A retirement plan error was discovered
Missed eligibility, deferrals, matching contributions, or compensation definitions may require tax issue triage and organized support.
Retirement-plan tax issue support →09
Executive pay at a tax-exempt organization is under review
Compensation across related entities, deferred amounts, severance, and reporting may raise federal excise-tax questions.
Tax-exempt executive-pay matters →10
Diligence uncovered historical compensation exposure
A sale, investment, restructuring, or IPO process surfaced payroll, equity, owner-pay, or change-in-control questions.
Transaction-related tax review →11
Payroll, HR, benefits, and accounting data conflict
Different systems report different workers, amounts, dates, or tax treatment, making it difficult to explain the position.
Cross-record reconciliation →12
ASC 718 or ASC 740 support is needed
Company-prepared share-based compensation or income-tax accounting analyses need an experienced review or advisory perspective.
ASC 718 / ASC 740 review scope →Not every discrepancy creates a tax liability. GWD first reviews the facts, records, legal posture, and response deadlines to determine what the matter requires.
Why a focused review matters
The IRS sees the records as a connected story.
Facts, payment records, payroll filings, information returns, agreements, tax returns, and financial reporting may all inform an examination. A focused review helps identify what the IRS is asking, where the position is supported, and what needs a clear response.
Federal employment tax examinations may address whether compensation, wages, and taxes were reported accurately. IRS guidance also explains that S corporations must determine and report appropriate wages for shareholder-employees who perform services.
See how GWD supports controversy matters“Understand the issue. Read the record. Respond with a position grounded in the facts.”
- 01Arrangement and facts
- 02Payroll and tax records
- 03IRS issue development
- 04Administrative response
The practice focus
Controversy first. Review support where it fits.
GWD’s primary work is federal tax controversy analysis and authorized representation involving Compensation & Benefits and Employment Tax. Corporate experience with ASC 718 and ASC 740 supports separate review and advisory engagements.
Primary practice
Compensation & Benefits + Employment Tax
Issue analysis, examination support, response strategy, administrative advocacy, and professional-firm support when an IRS matter involves compensation, benefits, or employment tax.
- IRS examination and information requests
- Proposed adjustments and penalty matters
- Worker classification and payroll tax issues
- Executive compensation and benefit tax positions
Related review & advisory
ASC 718 and ASC 740
Review and advisory support informed by corporate tax, accounting, provision, and financial reporting experience.
- Review of company-prepared analyses
- Share-based compensation accounting and tax questions
- Tax provision materials and supporting workpapers
- Coordination of related tax reporting considerations
Who we help
For employers and the professionals beside them.
GWD works with organizations facing an IRS compensation or employment tax issue and with firms seeking focused technical support on a defined matter.
A
Closely held and middle-market employers
IRS questions about owner wages, distributions, contractors, taxable benefits, or payroll reporting.
B
Growing and transaction-active companies
Examination or diligence findings involving executive pay, equity compensation, workforce classification, or historical reporting.
C
Tax-exempt organizations
Federal tax controversy involving executive compensation, benefits, or related information reporting.
A defined engagement
Start with the notice, the issue, and the records.
Share a general description and any response deadline. Do not send taxpayer identification numbers, returns, transcripts, payroll files, or other sensitive records through this website or ordinary email.