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Are There Better Ways To Resolve Tax Disputes
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Book Synopsis Are There Better Ways to Resolve Tax Disputes, Conference on Alternative Dispute Resolution (1992) by : Federal Bar Association
Download or read book Are There Better Ways to Resolve Tax Disputes, Conference on Alternative Dispute Resolution (1992) written by Federal Bar Association and published by . This book was released on 1992-01-01 with total page 259 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Are There Better Ways to Resolve Tax Disputes? by :
Download or read book Are There Better Ways to Resolve Tax Disputes? written by and published by . This book was released on 1992 with total page 222 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Resolution of International Tax Disputes by : David Rüll
Download or read book The Resolution of International Tax Disputes written by David Rüll and published by Kluwer Law International B.V.. This book was released on 2024-06-10 with total page 263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right for an institutionalised international tax dispute resolution mechanism that takes into account the interests of taxpayers, states, and the public and allows for a swift and binding resolution of international tax disputes ¬– exactly what this timely and thoroughgoing book offers. A comprehensive overview of existing international tax dispute resolution mechanisms – and an analysis of their procedural rules, advantages, and disadvantages – leads to a deeply informed proposal on how they can be further developed in a way that ensures greater fairness and equity for all stakeholders. Among the lines of conflict that characterise international tax disputes, the author sheds clear light on how improvements in the design of dispute resolution mechanisms may be found. This includes these questions: How should a dispute resolution mechanism be structured? Should there be a mandatory resolution if the states cannot agree? In which way should taxpayers participate in the procedure? Should agreements and decisions be published? Should there be an institution to administer the procedure? The book concludes with a draft convention that would implement the author’s suggestions. Tax lawyers and other tax professionals worldwide, as well as national tax authorities, will benefit greatly from this book. They will deepen their understanding of the variety of existing tax dispute resolution mechanisms and discover ways to strengthen them. Academics will find ample room to reflect on the key design elements of such mechanisms and how to improve them.
Book Synopsis Dispute Resolution Under Tax Treaties by : Zvi Daniel Altman
Download or read book Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and published by IBFD. This book was released on 2005 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
Book Synopsis Internal Revenue Service IRS initiatives to resolve disputes over tax liabilities : report to the Chairman, Subcommittee on Oversight, Committee on Ways and Means, House of Representatives by :
Download or read book Internal Revenue Service IRS initiatives to resolve disputes over tax liabilities : report to the Chairman, Subcommittee on Oversight, Committee on Ways and Means, House of Representatives written by and published by DIANE Publishing. This book was released on with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Tax Disputes and Litigation Review by : Simon Whitehead
Download or read book The Tax Disputes and Litigation Review written by Simon Whitehead and published by . This book was released on 2015 with total page 441 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Alternative Dispute Resolution and Tax Disputes by : Werner Haslehner
Download or read book Alternative Dispute Resolution and Tax Disputes written by Werner Haslehner and published by Edward Elgar Publishing. This book was released on 2023-04-28 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration has been promoted as the future of tax dispute resolution in recent years in line with the increase in complexity of international tax law. This authoritative book presents existing legal rules on the matter, provides a review of the arguments in favour of tax arbitration, discusses the practical and legal challenges for its wide-spread adoption and compatibility with existing domestic and international norms. It also answers key questions for the practical implementation of a modern tax arbitration system. Key Features: Comprehensive analysis of the existing tax treaty framework and their application to MAP and arbitration Up-to-date guidance on the best practices in alternative dispute resolution to ensure effective and efficient dispute resolution Original insights from dispute resolution mechanisms found in non-tax areas such as trade and investment law In-depth discussion of primary and secondary EU law rules on tax dispute resolution, including implications of EU general principles, fundamental rights and internal market rules Identifying some of the new issues in tax arbitration and offering views on how to tackle them in the most appropriate way, this book will be a key resource for tax law practitioners looking for the latest insights on how to navigate the legal framework for alternative tax dispute resolution. Students and academics focusing on commercial and tax law will also benefit from this detailed guide.
Book Synopsis Federal Tax Litigation by : Susan A. Berson
Download or read book Federal Tax Litigation written by Susan A. Berson and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax lawyers across the country have at least one thing in common--the feeling of frustration when trying to figure out the hows and whys of IRS action or inaction. Federal Tax Litigation helps to lift the veil of mystery. Written by a former litigator for the Tax Division of the Justice Department, this book offers an insider's perspective on both the legal issues and practical considerations involved in handling a federal tax controversy. It presents a comprehensive approach to tax litigation, covering audit, appeal, problems resolution office, collection and subsequent judicial proceedings involving the Justice Department. You'll find coverage of every aspect of federal tax disputes, including: handling tax controversies at all levels of the IRS; alternative dispute resolution procedures; asserting the "innocent spouse defense"; representing a client who is the target of the Criminal Investigation Division; refuting jeopardy assessments; suits against the federal government for overpayments; establishing "reasonable cause" for failure to pay; fighting government suits for recovery of erroneous refunds; recovery of damages for improper government disclosures of tax return information; taxpayer recovery of attorney's fees; tax debts that may be discharged in bankruptcy; grand jury matters; and more. Whether you are experienced or new to the field, Federal Tax Litigation will show you what to expect and help you advise clients in difficult situations. Don't miss this essential guide used in government, private practice and law schools across the country!
Book Synopsis Income Tax Disputes Involving Loss Years : Pittfalls, Foibles, and Possible Reforms by : M.H. Lubetsky
Download or read book Income Tax Disputes Involving Loss Years : Pittfalls, Foibles, and Possible Reforms written by M.H. Lubetsky and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax disputes involving losses can be challenging to resolve owing to two longstanding principles, commonly known as "the nil assessment rule" and "the New St James principle". The nil assessment rule bars taxpayers from objecting to assessments that result in no tax being payable - including both loss years and profitable years where income is completely offset by carryovers. The New St James principle provides, essentially, that loss years or years with no tax payable never become statute-barred. Because the nil assessment rule and the New St James principle can prevent the resolution of disputes over tax loss balances in a timely manner, Parliament amended the Income Tax Act in 1977 so as to allow, in certain situations, for the issuance by the minister of national revenue of a notice of determination of losses (NODL) for a given taxation year. Once issued, a NODL can be objected to or appealed in basically the same manner as an assessment and, subject to any objection or appeal, becomes binding upon the minister and the taxpayer. However, the existence of a parallel but distinct system for resolving loss disputes leaves gaps that result in a range of procedural traps for taxpayers. Taxpayers caught in these traps can potentially end up losing their rights to object to or appeal disputed income adjustments, reviving statute-barred issues, or being required to pay arrears interest on extinguished tax debts. This article explores some of these traps, showing how they arise and what a taxpayer might do to avoid being caught by them. It also discusses whether the time has come to reform the nil assessment rule and/or the New St James principle so as to allow disputes involving losses to be resolved more readily by the Tax Court of Canada, and proposes several possible reforms.
Book Synopsis Income Tax Disputes Involving Loss Years by : Michael H. Lubetsky
Download or read book Income Tax Disputes Involving Loss Years written by Michael H. Lubetsky and published by . This book was released on 2019 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax disputes involving losses can be challenging to resolve owing to two longstanding principles, commonly known as "the nil assessment rule" and "the New St James principle." The nil assessment rule bars taxpayers from objecting to assessments that result in no tax being payable--including both loss years and profitable years where income is completely offset by carryovers. The New St James principle provides, essentially, that loss years or years with no tax payable never become statute-barred.Because the nil assessment rule and the New St James principle can prevent the resolution of disputes over tax loss balances in a timely manner, Parliament amended the Income Tax Act in 1977 so as to allow, in certain situations, for the issuance by the minister of national revenue of a notice of determination of losses (NODL) for a given taxation year. Once issued, a NODL can be objected to or appealed in basically the same manner as an assessment and, subject to any objection or appeal, becomes binding upon the minister and the taxpayer.However, the existence of a parallel but distinct system for resolving loss disputes leaves gaps that result in a range of procedural traps for taxpayers. Taxpayers caught in these traps can potentially end up losing their rights to object to or appeal disputed income adjustments, reviving statute-barred issues, or being required to pay arrears interest on extinguished tax debts. This article explores some of these traps, showing how they arise and what a taxpayer might do to avoid being caught by them. It also discusses whether the time has come to reform the nil assessment rule and/or the New St James principle so as to allow disputes involving losses to be resolved more readily by the Tax Court of Canada, and proposes several possible reforms.
Book Synopsis The Collection Process (income Tax Accounts) by : United States. Internal Revenue Service
Download or read book The Collection Process (income Tax Accounts) written by United States. Internal Revenue Service and published by . This book was released on 1978 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Book Synopsis Examination of Returns, Appeal Rights, and Claims for Refund by : United States. Internal Revenue Service
Download or read book Examination of Returns, Appeal Rights, and Claims for Refund written by United States. Internal Revenue Service and published by . This book was released on 1978 with total page 8 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing and Dispute Resolution by : Anuschka Bakker
Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
Book Synopsis Alternative Dispute Resolution and Tax Disputes by : Werner Haslehner
Download or read book Alternative Dispute Resolution and Tax Disputes written by Werner Haslehner and published by Edward Elgar Publishing. This book was released on 2023-01-20 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration has been promoted as the future of tax dispute resolution in recent years in line with the increase in complexity of international tax law. This authoritative book presents existing legal rules on the matter, provides a review of the arguments in favour of tax arbitration, discusses the practical and legal challenges for its wide-spread adoption and compatibility with existing domestic and international norms. It also answers key questions for the practical implementation of a modern tax arbitration system.
Book Synopsis Effectively Representing Your Client Before the IRS by : T. Keith Fogg
Download or read book Effectively Representing Your Client Before the IRS written by T. Keith Fogg and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Collection Appeal Rights written by and published by . This book was released on 2000 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:
