IRS Chief of Appeals Sheldon Kay returned to private practice with Sutherland, Asbill & Brennan this month after two years with the tax authority. International Tax Review took the opportunity to catch up with Kay to discover the latest developments within the IRS Office of Appeals and to get some advice for taxpayers on resolving disputes more efficiently.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions