PLI Publishes International Tax Controversies: A Practical Guide

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Nov 05, 2014, 12:00 ET

NEW YORK, Nov. 5, 2014 /PRNewswire-USNewswire/ -- Practising Law Institute (PLI) announces the release of their newest book, International Tax Controversies: A Practical Guide. Authored by a team of experts from Steptoe & Johnson LLP, International Tax Controversies provides a detailed roadmap for resolving cross-border tax issues.

The new book is organized into three parts: "International Tax Audits and Appeals," "Government-to-Government Cooperation" and "Litigating International Tax Cases."

In Part 1, "International Tax Audits and Appeals," the authors – Philip R. West, J. Walker Johnson, Michael Durst and Amanda Varma – offer clear guidance on handling international examinations, IRS appeals and special appeals procedures. They walk readers through pre-audit planning, including document retention and spoliation. They shed light on transfer pricing issues, as well as concerns regarding attorney-client privilege and other protections in the cross-border context. Additionally, the authors highlight special document issues in international examinations, including information document requests (IDRs) and administrative summonses.

In Part 2, "Government-to-Government Cooperation," the authors outline and explain mutual agreement procedures (MAPs), which provide taxpayers the opportunity to ask the "competent authorities" of countries taking conflicting positions to reach an agreement that will protect them from double taxation. Additionally, the authors analyze advance pricing agreements (APAs), providing detailed guidance on the process by which taxpayers may obtain an APA.

In Part 3, "Litigating International Tax Cases," the authors outline post-appeals litigation options. Entire chapters are also dedicated to discovery in international tax cases and trial and appellate practice.

The single-volume International Tax Controversies: A Practical Guide is $325 and is available for a 30-day free examination.

About Practising Law Institute (PLI)

Practising Law Institute (PLI) is the most prestigious nonprofit continuing legal education and training organization dedicated to providing the legal and business community with the most current intelligence available.

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SOURCE Practising Law Institute