Practising Law Institute (PLI) has announced the release of their newest Treatise title, International Tax Controversies: A Practical Guide.
The new International Tax Controversies: A Practical Guide, authored by a team of experts from Steptoe & Johnson LLP, provides a detailed roadmap for resolving cross-border tax issues.
The new book is organized into three parts: “International Tax Audits and Appeals,” “Government-to-Government Cooperation” and “Litigating International Tax Cases.”
In Part 1, “International Tax Audits and Appeals,” the authors – Philip R. West, J. Walker Johnson, Michael Durst and Amanda Varma – offer clear guidance on handling international examinations, IRS appeals and special appeals procedures. They walk readers through pre-audit planning, including document retention and spoliation. They shed light on transfer pricing issues, as well as concerns regarding attorney-client privilege and other protections in the cross-border context. Additionally, the authors highlight special document issues in international examinations, including information document requests (IDRs) and administrative summonses.
In Part 2, “Government-to-Government Cooperation,” the authors outline and explain mutual agreement procedures (MAPs), which provide taxpayers the opportunity to ask the “competent authorities” of countries taking conflicting positions to reach an agreement that will protect them from double taxation. Additionally, the authors analyze advance pricing agreements (APAs), providing detailed guidance on the process by which taxpayers may obtain an APA.
In Part 3, “Litigating International Tax Cases,” the authors outline post-appeals litigation options. Entire chapters are also dedicated to discovery in international tax cases and trial and appellate practice.
International Tax Controversies: A Practical Guide is a much-needed guide providing skillful guidance to resolving U.S. international tax controversies.
If you’d like to order International Tax Controversies: A Practical Guide, please email the PLI Library Help Desk or call 877-900-5291.