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 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