If enforcement staff continue to be cut, O’Donnell said there will be fewer audits, which may in turn influence the behavior of taxpayers. O’Donnell sees compliance more likely dropping with private companies, high wealth individuals and small businesses rather than large public companies which have auditors and legal advisors. Dispute prevention routesFor CFOs interested in tax certainty and avoiding tax disputes with the IRS, there are options. Currently there are about 120 large companies across the U.S. that are taking part in the program. “I think that gets down to the individual risk calculus of a company, their CFO, their head of tax.