Download or read book Settling Large Tax Disputes written by Great Britain. National Audit Office and published by The Stationery Office. This book was released on 2012-06-14 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt: The National Audit Office has concluded, on the basis of an examination by former High Court tax judge Sir Andrew Park of five large tax settlements, that all five settlements were reasonable and at least one may have been better than reasonable. However, there were concerns about the processes by which the settlements were reached and over poor internal communication of the reasons for settlement which resulted in a loss of confidence in the settlements, both internally and externally. These large settlements are complex and there is no clear answer to what represents the 'right' tax liability. In each case, there was a range of justifiable positions the Department might have taken. The NAO's examination included consideration of whether the settlement in each case was as good as or better than the outcome that might be expected from litigation, taking into account the risks, cost, uncertainties and timescale of that option. It is not clear that all settlements were fully compatible with the Department's Litigation and Settlement Strategy. For instance, there are some disputes where the only possible outcomes are either that the taxpayer owes nothing or that it owes the full amount. In these circumstances, the Department's Litigation and Settlement Strategy does not permit 'splitting the difference'. The Department has acknowledged that its governance processes need strengthening and is introducing new arrangements, including the appointment of an assurance Commissioner, who will approve all large settlements

Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

Download or read book The Collection Process income Tax Accounts written by United States. Internal Revenue Service and published by . This book was released on 1978 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.

Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.

Download or read book Tax Withholding and Estimated Tax written by and published by . This book was released on 1993 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Closing the tax gap written by Great Britain: Parliament: House of Commons: Treasury Committee and published by The Stationery Office. This book was released on 2012-03-09 with total page 96 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Treasury Committee report considers HM Revenue & Custom's past work in ensuring tax compliance and concludes that while progress has been made, there is still work to be done. HMRC defines the tax gap as the difference between tax collected and the tax that should be collected (the theoretical liability). The theoretical tax liability represents the tax that would be paid if all individuals and companies complied with both the letter of the law and HMRC's interpretation of the intention of Parliament in setting law (referred to as the spirit of the law). Enabling voluntary compliance is the most efficient way of closing the tax gap, and HMRC must ensure that all those who wish to comply with their tax obligations are able to do so. Part of the process of encouraging voluntary compliance is demonstrating that HMRC treats all taxpayers fairly, whether they are individuals, small businesses, or large corporations. The tax system should be simplified to make compliance easier. HMRC's recent announcement of ways it intends to improve its processes for settling tax disputes is a step forward in the context of wider questions needing to be answered about the accountability structures of HMRC. HMRC's calculation of the tax gap is flawed and risks focusing the minds of its employees on the wrong task: maximising revenue at all cost rather than ensuring that all taxpayers pay the right amount of tax.

Download or read book Civil Tax Penalties written by Alan J. Tarr and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... analyzes the many civil tax penalties that can be imposed for various tax offenses. These penalties are designed to regulate the conduct of preparers, payors and tax-exempt entities, in addition to that of taxpayers. The Internal Revenue Service Penalty Handbook (Chapter 20.1 of the Internal Revenue Manual) is intended to ensure that the penalties are applied uniformly.

Download or read book Examination of Returns Appeal Rights and Claims for Refund written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 8 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Co operative Compliance A Framework From Enhanced Relationship to Co operative Compliance written by OECD and published by OECD Publishing. This book was released on 2013-07-29 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report examines the relationship between large business taxpayers and revenue bodies, five years on from the publication of the FTA’s Study into the Role of Tax Intermediaries.

Download or read book Tax Law State Building and the Constitution written by Dominic de Cogan and published by Bloomsbury Publishing. This book was released on 2020-08-06 with total page 183 pages. Available in PDF, EPUB and Kindle. Book excerpt: This monograph looks at how tax is intertwined with constitutional law and the state in the UK. It looks at a variety of topics including tax devolution, scrutiny and reform of tax legislation, the protection of taxpayers and the domestic legal processing of international rules and problems. Tax Law, State-Building and the Constitution presents and interrogates five key claims. First, there is a clear overlap between the concerns of tax and constitutional lawyers. Secondly, the tax system is being deeply affected by the fast pace of constitutional change. Thirdly, decisions taken in the tax field are likely to have a reverse influence on the evolution of the constitution. Fourthly, these relationships are heavily context-dependent, with tax making all the difference to some ongoing constitutional controversies whilst having very little to do with others. Fifthly, by acknowledging tax as an important moving part within the contemporary constitution we might understand both tax and constitutional law a little better. The book therefore contributes to deeper theoretical debates on the identity of tax law as a discipline, the relevance of tax to public lawyers, the meaning of state-building in the recent history of a developed country and the importance of public finances to a wider sense of 'what is going on'. These are questions that ought to command the attention of tax and constitutional law academics as well as policy makers and reformers. Runner-up of the 2022 SLS Peter Birks Prize for Outstanding Legal Scholarship.

Download or read book United States Attorneys Manual written by United States. Department of Justice and published by . This book was released on 1988 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Philosophical Foundations of Tax Law written by Monica Bhandari and published by Oxford University Press. This book was released on 2017-02-09 with total page 375 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax law changes at a startling rate - not only does societal change bring with it demands for change in the tax system, but changes in the political climate will force change, as will many other competing pressures. With this pace of change, it is easy to focus on the practical and forget the core underpinnings of the tax system and their philosophical justifications. Taking a pause to remind ourselves of those principles and how they can operate in the modern tax system is crucial to ensuring that the tax system does not diverge too far from what it should be or could be. It is essential to understand the answers to some of the seemingly basic questions that surround tax before we can even begin to think about what a tax system should look like. This collection brings together major themes and difficult questions in the philosophical foundations of tax law. The chapters consider practical issues such as justification, enforcement, design, and mechanics, and provide a full and coherent analysis of the basis for tax law. Philosophical Foundations of Tax Law allows the reader to consider how tax systems should move forward in the modern world, with a sound philosophical basis, to provide the practical tax system that the state requires and citizens deserve.

Download or read book Internal Revenue Service IRS initiatives to resolve disputes over tax liabilities report to the Chairman Subcommittee on Oversight Committee on Ways and Means House of Representatives written by and published by DIANE Publishing. This book was released on with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Glorification of Plunder written by Malcolm James and published by Spiramus Press Ltd. This book was released on 2017-09-04 with total page 238 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is about two things: tax and power. The processes through which tax law is formulated, involve more than the formal legislative and judicial processes which result in statute and case law. Tax law is an expression of tax policy, which is subjective and a heterogeneous product of states, cultures and politics. Regarding taxation as a branch of either black letter law or orthodox economics ignore, or even deny, this subjectivity. This book explores the complex dynamics of the debates which inform tax policy, the interaction between tax and power and how power relations between various groups in society and between individuals and the state are manifested through tax system. This helps to explain why the rules, procedures and practices are all formulated to suit their interests of the most powerful groups in society. Taxation is a powerful lens through which to analyse relationships between individuals and the state, since history has shown that there is a longstanding power relationship between rulers and subjects, which is articulated through tax regimes. Tax can therefore be seen as a technology which mediates such tensions and relationships and the way that choices are made and conflicts are resolved can give valuable insights into societal power relationships.

Download or read book Tiley s Revenue Law written by Glen Loutzenhiser and published by Bloomsbury Publishing. This book was released on 2019-08-22 with total page 1647 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the ninth edition of John Tiley's major text on revenue law, covering the UK tax system, income tax, capital gains tax and inheritance tax, as well as incorporating sections dealing with corporation tax, international and European tax, savings and charities. This new edition is fully revised and updated with the latest case law, statutory and other developments, including Finance Act 2019. The book is designed for law students taking the subject in the final year of their law degree, or for more advanced courses, and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but also to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems. Copy the URL below to read a 2021 supplement highlighting new developments since the book's publication in 2019: https://www.bloomsbury.com/media/2v1ej5vw/tileys-revenue-law-supplement-2021.pdf

Download or read book Dispute Settlement Reports 2000 Volume 1 Pages 1 572 written by World Trade Organization and published by Cambridge University Press. This book was released on 2002-08-15 with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt: The authorized, paginated WTO Dispute Settlement Reports in English: cases for 2000.