As part of a continuing worldwide trend, the US Internal Revenue Service (IRS) is ramping up its efforts to deal with the international tax issues that arise as a result of increased cross-border trade. In the last year, the IRS has realigned its resources, focused attention on strategic issues, and begun to reshape its international tax administration. Barry Shott, Richard Barrett, and Jana Lessne, of PwC US, examine the implications of the IRS competent authority changes.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
All the tax partners elevated across the UK, US and Singapore were private client specialists, continuing a market trend of intense investment and competition