International tax controversy: New developments and opportunities
RECORDED WEBCAST |
The IRS is changing the way it audits international tax issues, making it even more critical that taxpayers have a strong game plan to manage an ongoing or potential IRS audit.
Our tax professionals will discuss new IRS developments that affect international tax controversy matters in this webcast. We will also address opportunities to pursue and pitfalls to avoid. Topics include:
- Cost-sharing arrangements and transfer pricing regulations after Altera v. Commissioner and eligibility for filing a protective claim
- The competent authority process as a method to mitigate double taxation
- New acknowledgment of facts information document request (IDR) process for cases heading to appeals or litigation
- Other IRS developments