Practitioners have said the decision to move responsibility for the US advance pricing agreement programme (APA) and mutual agreement procedure (MAP) from the Office of Chief Counsel to the IRS commissioner has as much to do with the faith in the ability of Mike Danilack, deputy commissioner (international) of the Large and Mid-Size Business Division (LB&I), as it has to do with efficiency.
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The firm demonstrated its sweet spot of litigation with an international twist with the recent win for the Danish tax authority…but it’s not a tax case
The AI platform, founded last year by two school friends, is partnering with challenger firms like Unity Advisory and A&M Tax to launch its own assault on the AI tax market