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Tax Disputes
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Book Synopsis Tax Litigation in Australia by : Pagone
Download or read book Tax Litigation in Australia written by Pagone and published by . This book was released on 2018-04 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a guide to tax disputes in Australia. It explains the process of tax objections and appeals, and the limitations to collateral challenges. Separate chapters consider the rules applicable to tax disputes brought in the Federal Court and in the Administrative Appeals Tribunal, and ancillary issues of discovery and access to information. The book aims also to provide helpful assistance to the practitioner and to students in the preparation of submissions, persuasive advocacy and the provision to courts and tribunals of useful expert evidence in support of disputed positions.
Book Synopsis Federal Tax Litigation by : Susan A. Berson
Download or read book Federal Tax Litigation written by Susan A. Berson and published by Law Journal Press. This book was released on 2001 with total page 1108 pages. Available in PDF, EPUB and Kindle. Book excerpt: This law book offers an insider's perspective on both the legal issues and practical considerations involved in handling a federal tax controversy.
Book Synopsis Reports of the United States Board of Tax Appeals by : United States. Board of Tax Appeals
Download or read book Reports of the United States Board of Tax Appeals written by United States. Board of Tax Appeals and published by . This book was released on 1934 with total page 1636 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Litigation Handbook by : Pump Court Tax Chambers
Download or read book Tax Litigation Handbook written by Pump Court Tax Chambers and published by Bloomsbury Professional. This book was released on 2023-05-25 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax Litigation Handbook authored by Pump Court Tax Chambers is the successor to the previously published Hamilton on Tax Appeals. It covers tax appeals process (First Tier Tribunal and Upper Tier litigation), including the types of decision that can be appealed and how an appeal can be brought. It also addresses procedures relating to other types of tax litigation, such as judicial review to the Upper Tier Tribunal, claims for professional negligence, insolvency procedures and High Court litigation. The rules are for remote hearings which have been more common in recent times are also covered. The procedures and principles for seeking costs before the First Tier Tribunal are covered in a separate chapter. All commentary is clearly presented with extensive referencing to relevant cases . The book will be of interest to those representing clients of all sizes in an appeal, or those considering appealing a decision.
Book Synopsis A Global Analysis of Tax Treaty Disputes by : Eduardo Baistrocchi
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Book Synopsis Reports of the U.S. Board of Tax Appeals by : United States. Board of Tax Appeals
Download or read book Reports of the U.S. Board of Tax Appeals written by United States. Board of Tax Appeals and published by . This book was released on 1926 with total page 1616 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Resolving Transfer Pricing Disputes by : Eduardo Baistrocchi
Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
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 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 Reports of the United States Board of Tax Appeals by :
Download or read book Reports of the United States Board of Tax Appeals written by and published by . This book was released on 1926 with total page 1554 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Reports of the United States Board of Tax Appeals by : United States. Board of Tax Appeals
Download or read book Reports of the United States Board of Tax Appeals written by United States. Board of Tax Appeals and published by . This book was released on 1928 with total page 1550 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Fundamentals of Federal Tax Procedure and Enforcement by : Allen D. Madison
Download or read book Fundamentals of Federal Tax Procedure and Enforcement written by Allen D. Madison and published by Aspen Publishing. This book was released on 2022-10-27 with total page 810 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written by a professor with experience on all sides of federal tax disputes, Fundamentals of Federal Tax Procedure and Enforcement provides students with a guide through the thicket of rules and procedures that comprise the federal tax system, helping them make sense of a seemingly random collection of dense rules and seemingly inaccessible entities governing federal tax procedure and enforcement. For ease of teaching and learning, Professor Madison breaks down the rules and concepts of tax procedures and enforcement into four distinct parts based on the decisions and determinations the parties to a tax dispute must make, as well as the rules affecting those decisions. Professors and students will benefit from: A new perspective on how to present the tax system to students A bird’s eye view of the tax system while drilling deep into essential topics A standalone resource—all necessary statutes and regulations within the text Probing notes and questions after each case that help put the cases in context A balance of technical language—less technical than the highly technical language used by tax practitioners, but more technical than law students have yet been exposed to in their legal studies
Book Synopsis Federal Income Tax Litigation in Canada by : A. Christina Tari
Download or read book Federal Income Tax Litigation in Canada written by A. Christina Tari and published by . This book was released on 2010 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Rules of Practice Before the United States Board of Tax Appeals by : United States. Tax Court
Download or read book Rules of Practice Before the United States Board of Tax Appeals written by United States. Tax Court and published by . This book was released on 1924 with total page 346 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Exploring the Nexus Doctrine In International Tax Law by : Ajit Kumar Singh
Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
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 Flexible Multi-tiers Dispute Resolution in International Tax Disputes by : Pasquale Pistone
Download or read book Flexible Multi-tiers Dispute Resolution in International Tax Disputes written by Pasquale Pistone and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
