Get International Tax Controversies: A Practical Guide (2017 PDF

By Philip R. West,J. Walker Johnson,Michael Durst,Amanda Varma

With the U.S. Justice division taking an ever-closer examine cross-border transactions and their tax implications, the recent International Tax Controversies: a pragmatic Guide presents an in depth roadmap to tips to organize for a tax audit that consists of a world part. developing and keeping the correct transaction-related documentation, and knowing what extra documentation should be wanted for a global exam, is essential to a winning audit.

International Tax Controversies describes the method of the way a world audit proceeds, together with offering info on:

How the IRS audit group is chosen
What the bounds are of the scope of the examination
The kind of exam that may be carried out and the types of records that might have to be supplied by way of the taxpayer and 3rd parties
The types of enforcement techniques which may be brought

In foreign tax occasions, there are frequently conflicting positions taken by means of the U.S. inner assessment provider and a non-U.S. tax authority. Tax treaties containing mutual contract strategies (MAPs) are frequently invoked to guard the taxpayer from paying double taxes. International Tax Controversies describes the method in which MAPs will be invoked and a binding answer created.

As such a lot disagreements among foreign taxing entities contain move pricing concerns, there's usually a chance to procure an develop pricing contract (APA) to guard the taxpayer. International Tax Controversies analyzes the APA strategy, supplying an in depth consultant on facilitating the method to your consumer. It additionally describes the various tax info alternate treaties and agreements that the U.S. has entered into, and the effect they've got had at the U.S. taxpayer.

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