David Swenson, global leader, PwC’s tax controversy and dispute resolution network, asserts that given the current environment, effectively managing and resolving tax audits and disputes worldwide should involve both coordinated global strategic planning and local tactical implementation.
Paul Harrison of KPMG provides insight on how to ensure European taxpayers are well equipped to face any situation and help maximise their chance of a favourable outcome when they become involved in a tax audit or dispute.
The taxation of income earned by controlled and related foreign companies has become an increasingly important question as Brazil’s economy develops, since a growing number of Brazilian businesses now have investments in foreign companies that constitute a relationship of control explains Maurício Pereira Faro of Barbosa Müssich & Aragão.
Thomas Durham, Brian Kittle and William Schmalzl of Mayer Brown explain that section 199, a measure intended to stimulate job growth, has instead caused headaches for both officials and taxpayers and created unnecessary volumes of tax controversy in the US.