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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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said