The US Supreme Court heard the oral arguments in the Woods dispute last month, which deals with whether valuation misstatement penalties are applicable in tax shelter cases. Professor David Shakow, of the University of Pennsylvania Law School and counsel at Chamberlain, Hrdlicka, White, Williams & Aughtry, who filed an amicus brief against the government in the case, explains why taxpayers hope the court’s judgment will help clarify two controversial areas of US tax law.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap