In her first speech before the Tax Executive Institute (TEI) since being named commissioner of the large and medium-sized business (LMSB) division at the Internal Revenue Service (IRS) last November, Heather Maloy responded to the unease that many large corporate taxpayers feel in the wake of IRS announcement 2010-09.
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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