United States

Tax Dispute Resolution Quarterly

Tax Dispute Resolution Quarterly aggregates hot topics, uncovers dominant trends, and offers you value-added insight from our professionals who work and monitor activity in the United States and abroad. Each issue is filled with important and timely articles related to tax enforcement trends, IRS practice and procedure, and state and local tax compliance matters.

The Summer 2014 issue is filled with articles on changes and developments related to potential tax disputes and controversies. Some other the articles included in this issue are:

  • Does Clarke offer real hope for challenging IRS summonses?
  • Goodbye Circular 230 legend, hello new competence concept
  • Don't blow the SOL for filing 2010 amended returns
  • Have undisclosed foreign assets? IRS has a deal for you!
  • Top transfer pricing disputes specialist Wrappe joins KPMG

Recent Issues

Spring 2014 

Some of the articles included in this issue are:

  • LB&I: Does de-coordinating issue papers mean disappearing guidance?
  • Overview of transfer pricing audit roadmap
  • Horizontal monitoring: End of inefficient tax audits?
  • Controversial Tax Court Rent-A-Center insurance case

Winter 2013

Some of the articles included in this issue are:

  • LB&I announces strict procedures to enforce delinquent information document requests
  • Mitigating the risk of whistle blowing: Additional tax not only cost
  • New rules for claiming section 199 benefits and burdens of ownership
  • Focus on the new UK general anti-abuse rule