Download or read book Tax Litigation in Australia written by Pagone and published by . This book was released on 2018-04 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a guide to tax disputes in Australia. It explains the process of tax objections and appeals, and the limitations to collateral challenges. Separate chapters consider the rules applicable to tax disputes brought in the Federal Court and in the Administrative Appeals Tribunal, and ancillary issues of discovery and access to information. The book aims also to provide helpful assistance to the practitioner and to students in the preparation of submissions, persuasive advocacy and the provision to courts and tribunals of useful expert evidence in support of disputed positions.
Download or read book Reports of the United States Board of Tax Appeals written by United States. Board of Tax Appeals and published by . This book was released on 1928 with total page 1560 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Federal Tax Litigation written by Susan A. Berson and published by Law Journal Press. This book was released on 2001 with total page 1110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This law book offers an insider's perspective on both the legal issues and practical considerations involved in handling a federal tax controversy.
Download or read book Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and published by IBFD. This book was released on 2005 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Download or read book The Resolution of International Tax Disputes written by David Rüll and published by Kluwer Law International B.V.. This book was released on 2024-06-10 with total page 263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right for an institutionalised international tax dispute resolution mechanism that takes into account the interests of taxpayers, states, and the public and allows for a swift and binding resolution of international tax disputes ¬– exactly what this timely and thoroughgoing book offers. A comprehensive overview of existing international tax dispute resolution mechanisms – and an analysis of their procedural rules, advantages, and disadvantages – leads to a deeply informed proposal on how they can be further developed in a way that ensures greater fairness and equity for all stakeholders. Among the lines of conflict that characterise international tax disputes, the author sheds clear light on how improvements in the design of dispute resolution mechanisms may be found. This includes these questions: How should a dispute resolution mechanism be structured? Should there be a mandatory resolution if the states cannot agree? In which way should taxpayers participate in the procedure? Should agreements and decisions be published? Should there be an institution to administer the procedure? The book concludes with a draft convention that would implement the author’s suggestions. Tax lawyers and other tax professionals worldwide, as well as national tax authorities, will benefit greatly from this book. They will deepen their understanding of the variety of existing tax dispute resolution mechanisms and discover ways to strengthen them. Academics will find ample room to reflect on the key design elements of such mechanisms and how to improve them.
Download or read book Fundamentals of Federal Tax Procedure and Enforcement written by Allen D. Madison and published by Aspen Publishing. This book was released on 2022-10-27 with total page 810 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written by a professor with experience on all sides of federal tax disputes, Fundamentals of Federal Tax Procedure and Enforcement provides students with a guide through the thicket of rules and procedures that comprise the federal tax system, helping them make sense of a seemingly random collection of dense rules and seemingly inaccessible entities governing federal tax procedure and enforcement. For ease of teaching and learning, Professor Madison breaks down the rules and concepts of tax procedures and enforcement into four distinct parts based on the decisions and determinations the parties to a tax dispute must make, as well as the rules affecting those decisions. Professors and students will benefit from: A new perspective on how to present the tax system to students A bird’s eye view of the tax system while drilling deep into essential topics A standalone resource—all necessary statutes and regulations within the text Probing notes and questions after each case that help put the cases in context A balance of technical language—less technical than the highly technical language used by tax practitioners, but more technical than law students have yet been exposed to in their legal studies
Download or read book The Tax Disputes and Litigation Review written by Simon Whitehead and published by . This book was released on 2015 with total page 441 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Litigation Handbook written by Pump Court Tax Chambers and published by Bloomsbury Professional. This book was released on 2023-05-25 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax Litigation Handbook authored by Pump Court Tax Chambers is the successor to the previously published Hamilton on Tax Appeals. It covers tax appeals process (First Tier Tribunal and Upper Tier litigation), including the types of decision that can be appealed and how an appeal can be brought. It also addresses procedures relating to other types of tax litigation, such as judicial review to the Upper Tier Tribunal, claims for professional negligence, insolvency procedures and High Court litigation. The rules are for remote hearings which have been more common in recent times are also covered. The procedures and principles for seeking costs before the First Tier Tribunal are covered in a separate chapter. All commentary is clearly presented with extensive referencing to relevant cases . The book will be of interest to those representing clients of all sizes in an appeal, or those considering appealing a decision.
Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Download or read book Federal Tax Litigation written by Marvin Joseph Garbis and published by . This book was released on 1991 with total page 708 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume provides forms and detailed explanations to guide the practitioner in drafting pleadings and commonly encountered motions in Tax Court cases and tax refund suits. Procedural rules and decisions in tax refund litigation in all forums are cited and explained in the work.
Download or read book International Tax Disputes written by Hans Mooij and published by Edward Elgar Publishing. This book was released on 2024-06-05 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bringing together global experts from diverse legal backgrounds, this comprehensive book offers a rigorous analysis of the complexity of resolving and preventing international tax disputes, covering arbitration, mediation, and dispute management. Presenting an authoritative overview of international tax disputes, this book will be indispensable to practitioners in corporate and international tax, controversy and dispute specialists, and investment arbitration lawyers.
Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
Download or read book Federal Income Tax Litigation in Canada written by A. Christina Tari and published by . This book was released on 2010 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Alternative Dispute Resolution and Tax Disputes written by Werner Haslehner and published by Edward Elgar Publishing. This book was released on 2023-01-20 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration has been promoted as the future of tax dispute resolution in recent years in line with the increase in complexity of international tax law. This authoritative book presents existing legal rules on the matter, provides a review of the arguments in favour of tax arbitration, discusses the practical and legal challenges for its wide-spread adoption and compatibility with existing domestic and international norms. It also answers key questions for the practical implementation of a modern tax arbitration system.
Download or read book The Tax Disputes and Litigation Review written by Simon Whitehead and published by . This book was released on 2020 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A Practical Guide to Tax Disputes written by Adam Craggs and published by . This book was released on 2024-03 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
