Erin M. Collins joined the Taxpayer Advocate Service as the third National Taxpayer Advocate in March 2020. Prior to becoming the National Taxpayer Advocate, she was the Tax Managing Director in charge of KPMG’s Tax Controversy Services practice for the Western area until her retirement in April 2019. She has more than 35 years of experience handling controversies at all levels of the IRS, including the examination, appeals and chief counsel functions, as well as representing both foreign and domestic corporations on a wide range of technical and procedural issues.
Throughout her career, she represented thousands of individuals, partnerships, small companies and corporate taxpayers on technical and procedural tax matters. She has represented clients in federal examinations and IRS appeals on domestic and international tax issues, including transfer pricing disputes, foreign tax credits, research and experimentation credit claims, net operating loss utilization calculations, restructurings, treaty interpretations, executive compensation, and application of accounting methods.
Erin has wide-ranging experience with alternative dispute resolution procedures such as Pre-Filing Agreements, Fast Track settlement, post-appeals mediations, and advance rulings procedures to resolve difficult or uncertain federal tax issues at the earliest possible stage of the proceedings. In addition to providing federal controversy representation, Erin consulted with clients on federal tax procedure and substantive federal tax issues affecting the establishment or review of tax provisions pursuant to Accounting Standards Codification (ASC) 740. She assisted clients in evaluating reserves, including interest and penalties accruing on federal and state tax provisions.
Prior to joining KPMG, Erin was an attorney in the Office of Chief Counsel for the Internal Revenue Service. She was the Industry Counsel for Savings and Loans during the time of the S&L crisis. Over a six-year period, she worked very closely with the Treasury Department, the Commissioner, the Office of Chief Counsel and the Federal Deposit Insurance Corporation and Resolution Trust Corporation. In that role, she helped craft an outside-the-box solution focusing on the policy and administrative tax consequences of the S&L crisis consistent with the congressional intent of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA). The inter-agency agreement resulted in reducing the tax burden and administrative challenges for the IRS, the Treasury Department, and insolvent institutions while still complying with Congressional mandates.
As a Special Trial Attorney for the IRS, Erin was responsible for the development and litigation of high-profile, complex tax cases. In both 1995 and 1997, she received Chief Counsel’s highest award, the National Litigation Award. In 1993 received the Western Region’s highest Litigation Award for her outstanding achievements.
She has represented several clients before the U.S. Tax Court. Erin represented the government in several significant and complex tax cases, including DHL v. Commissioner (transfer pricing), Bell Federal v. Commissioner (loan origination points), Estate of Bullard v. Commissioner (estate tax), and Snow Manufacturing v. Commissioner (accumulated earnings).
Erin was the co-author of Practising Law Institute’s IRS Practice and Procedure Deskbook and has spoken frequently on IRS practice, procedure, controversy, and litigation matters before many professional organizations, including Annual Bank Tax Institute, National Tax Conference for Savings Institutions, FDIC Annual Tax Conference, UCLA Annual Tax Controversy Institute, State Bar of California, Los Angeles County Bar, NYU Annual Tax Institute, USC Annual Tax Institute, CITE, and Tax Executive Institute.