International Tax Controversies is a practical guide to handling international tax audits and appeals, government-to-government cooperation and special dispute resolution mechanisms, and litigating international tax cases. Disputes with the IRS regarding international tax issues often present special issues in addition to those normally relevant in purely domestic tax controversies.

For example, questions may arise regarding the application of attorney-client privilege and other protections in the cross-border context. Where relevant documents, witnesses, and other information are held abroad, special procedures may be applicable. In addition, special dispute resolution mechanisms may be available in international tax disputes involving tax treaties and transfer pricing. Taxpayers should also be aware of the potential impact on the competent authority process of entering into closing agreements. Finally, country-by-country reporting data will be changed by the United States pursuant to bilateral competent authority arrangements (CAAs) entered into in connection with tax treaties and TIEAs that permit automatic exchanges of information.

International Tax Controversies explores these and other relevant issues in international tax cases, in addition to the issues and procedures that commonly arise in U.S. federal tax audits (whether or not focused on international issues).

This essential treatise is available on PLI PLUS. If you would like to order a print copy, please contact libraryrelations@pli.edu.