Strategies For Tax Litigation
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Strategies For Tax Litigation
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Author : WEST GROUP
language : en
Publisher: Aspatore Books
Release Date : 2011
Strategies For Tax Litigation written by WEST GROUP and has been published by Aspatore Books this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Law categories.
Winning Legal Strategies For Tax Law
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Author :
language : en
Publisher:
Release Date : 2005
Winning Legal Strategies For Tax Law written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Business enterprises categories.
Resolving Your Tax Issues
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Author : Sean Hu
language : en
Publisher: FriesenPress
Release Date : 2023-08-24
Resolving Your Tax Issues written by Sean Hu and has been published by FriesenPress this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-08-24 with Business & Economics categories.
No one wants to have tax issues. However, if you do find yourself needing assistance with Canadian tax problems, Resolving Your Tax Issues details the processes and strategies you can use to resolve issues concerning income tax, GST/HST, and payroll taxes administered by the Canada Revenue Agency (CRA). As there are a growing number of tax cases where taxpayers represent themselves (or are represented by their accountants), Hu has written the book he needed when he found himself in the same situation. Providing information to help you resolve your CRA tax issues and achieve your goals at each stage of the tax dispute process, this book addresses three key themes: 1. Tax dispute resolution processes and strategies for taxpayers 2. The “rules of the game” for tax dispute resolution 3. Commonly disputed tax issues and their legal tests The tax issue resolution processes discussed throughout Resolving Your Tax Issues are divided into two categories: non-dispute processes (filing a return, changing a return, Taxpayer Relief Provisions, and the Voluntary Disclosure Program) and dispute processes (audit, objection, and appeal). Hu has diligently selected the most useful and relevant information, adding meticulous case studies, thorough analysis, and detailed strategies to inspire readers, including: • Taxpayers wanting to resolve their own tax issues and represent themselves in the tax dispute process • Accountants intending to represent their clients in resolving their tax issues • Lawyers planning to enter taxation practice • Consultants, educators, students, and other professionals with an interest in taxation who are intending to broaden their knowledge
Transfer Pricing And Dispute Resolution
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Author : Anuschka Bakker
language : en
Publisher: IBFD
Release Date : 2011
Transfer Pricing And Dispute Resolution written by Anuschka Bakker and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Dispute resolution (Law). categories.
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.
The Tax Disputes And Litigation Review
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Author : Simon Whitehead
language : en
Publisher:
Release Date : 2015
The Tax Disputes And Litigation Review written by Simon Whitehead and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with Dispute resolution (Law) categories.
Tax Planning For Domestic And Foreign Partnerships Llcs Joint Ventures And Other Strategic Alliances
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Author :
language : en
Publisher:
Release Date : 2005
Tax Planning For Domestic And Foreign Partnerships Llcs Joint Ventures And Other Strategic Alliances written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with International business enterprises categories.
Tax Litigation
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Author : David Wallen Chodikoff
language : en
Publisher:
Release Date : 2013-10-04
Tax Litigation written by David Wallen Chodikoff and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-10-04 with Comparative law categories.
'Tax Litigation' provides owners and leaders of business, general counsel, tax lawyers, accountants and members of the general public with ready access to the fundamentals of tax litigation in a multi-jurisdictional, comparative format. The information is provided by leading practitioners within the field from around the globe.
Dispute Resolution Under Tax Treaties
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Author : Zvi Daniel Altman
language : en
Publisher: IBFD
Release Date : 2005
Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Arbitration and award, International categories.
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.
Brics And International Tax Law
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Author : Peter Antony Wilson
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
Brics And International Tax Law written by Peter Antony Wilson and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-24 with Law categories.
With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.
Co Operative Compliance And The Oecd S International Compliance Assurance Programme
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Author : Ronald Hein
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-06-10
Co Operative Compliance And The Oecd S International Compliance Assurance Programme written by Ronald Hein and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-06-10 with Law categories.
Prominent among initiatives addressing the urgent need for a common understanding between multinational enterprises (MNEs) and national tax authorities about risks and risk assessment is the International Compliance Assurance Programme (ICAP), which provides a channel for MNEs to engage in simultaneous discussions with multiple national tax administrations, thus enhancing the potential for advance tax assurance. To a certain extent, the ICAP represents the internationalization of Co-operative Compliance frameworks which were, until then, restricted within the borders of single jurisdictions. This book is the first to investigate Co-operative Compliance alongside with the ICAP, describing developments in twelve countries (Australia, Austria, Canada, Germany, Italy, Japan, the Netherlands, Norway, Poland, Spain, the United Kingdom, and the United States). Following a general introduction, two opening perspectives on the ICAP are presented, one from the OECD and one from a participating tax administration (the Netherlands), leading to the twelve country reports and a special chapter on transfer pricing, which is the main issue in international tax disputes. Specific elements reviewed include the following: criteria to enter the programme; the range of taxes covered by the programme; real-time consultation procedures; appeal procedures within the programme; the possibility to ‘agree to disagree’ and to continue Co-operative Compliance even in cases of litigation; risk management strategies within tax authorities; corporate administrative compliance burden; and main sources of tax uncertainty. Country reports are contributed by tax professionals and tax academics experienced in dealing with Co-operative Compliance and the ICAP. Each report addresses the same questions, so that all the reports cover the same features of domestic relationship approaches and the ICAP. A final chapter reviews the collected contributions and offers some concluding remarks. Although the ICAP process probably will undergo further adjustments, it is certain that the road to more international cooperation between tax authorities and MNEs is now open. This timely book, as a comparative review of the implementation of the ICAP among leading jurisdictions active in global trade, provides matchless insights into trends, similarities, differences and their implications. It will be welcomed by all stakeholders in the international tax community, including lawyers, taxation authorities and academics.