By Ilya Somin,Todd J. Zywicki
By David Callies,W. Andrew, Jr. Gowder
By International Bar Association Staff
By Karen Burke
By Philip R. West,J. Walker Johnson,Michael Durst,Amanda Varma
With the U.S. Justice division taking an ever-closer examine cross-border transactions and their tax implications, the recent International Tax Controversies: a pragmatic Guide offers a close roadmap to the best way to arrange for a tax audit that contains a global part. growing and preserving the correct transaction-related documentation, and realizing what extra documentation should be wanted for a global exam, is key to a profitable audit.
International Tax Controversies describes the method of the way a world audit proceeds, together with supplying details on:
- How the IRS audit group is chosen
- What the bounds are of the scope of the examination
- The kind of exam that would be carried out and the types of records that might must be supplied by means of the taxpayer and 3rd parties
- The different types of enforcement approaches which may be brought
As so much disagreements among overseas taxing entities contain move pricing concerns, there's usually a chance to procure an boost pricing contract (APA) to guard the taxpayer. International Tax Controversies analyzes the APA technique, supplying an in depth advisor on facilitating the method to your customer. It additionally describes the various tax details alternate treaties and agreements that the U.S. has entered into, and the effect they've got had at the U.S. taxpayer.
By Wolfgang Schön (Ed.),Wolfgang Schön
Academic study indicates that famous principal-agent and capital industry difficulties are strongly motivated through tax issues. by contrast heritage, this quantity is the 1st to provide a fully-fledged review of the interdependence of tax and company governance. not just the fundamental political, felony and monetary questions but additionally significant issues like source of revenue dimension, shareholding constructions, company social accountability and tax safeguard disclosure are covered.
By James E. Hughes
By Michael J. Graetz
To such a lot americans, the U.S. tax code has turn into an enormous and confounding puzzle. In 1940, the directions to the shape 1040 have been approximately 4 pages long. at the present time they've got ballooned to greater than 100 pages, and the shape itself comprises greater than ten schedules and twenty worksheets. the entire tax code totals approximately 2.8 million words—about 4 occasions the size of War and Peace. during this exciting ebook, Michael Graetz continues that our tax code has turn into a tangle of loopholes, forms, and inconsistencies—a vast social software that fails checks of simplicity and equity. extra vital, our tax procedure has did not preserve speed with the altering financial system, developing burdens and wastes of assets that weigh our kingdom down.
Graetz deals an answer. think a global during which so much americans pay no source of revenue tax in any respect, and those that do take pleasure in a miles easier tax process—all this with no lowering executive sales or removal key incentives for employer-sponsored wellbeing and fitness care plans and pensions. As Graetz adeptly and obviously describes, this global is inside our grasp.
By Antonio Calisto Pato,Marlon Tavares Marques
By Beth E. Kinne,Erica Levine Powers