James Clare and Sean Akins of Latham & Watkins describe how taxpayers should best respond to an IRS approach under the Issue Tiering program
The current economic climate has prompted greater scrutiny of international tax issues by revenue authorities across the globe including the IRS in the US. Although cross-border transactions between the US and for instance the UK are commonplace the IRS has only a few targeted programs to identify and audit international tax issues. One such program is the IRS's Issue Tiering program which is designed to identify high-risk tax compliance issues assign those issues to one of three 'tiers' and coordinate the standardised development and resolution of those issues at a national level. Since the program's inception in 2006 it has gained traction...
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James Clare and Sean Akins of Latham & Watkins describe how taxpayers should best respond to an IRS approach under the Issue Tiering program
The current economic climate has prompted greater scrutiny of international tax issues by revenue authorities across the globe including the IRS in the US. Although cross-border transactions between the US and for instance the UK are commonplace the IRS has only a few targeted programs to identify and audit international tax issues. One such program is the IRS's Issue Tiering program which is designed to identify high-risk tax compliance issues assign those issues to one of three 'tiers' and coordinate the standardised development and resolution of those issues at a national level. Since the program's inception in 2006 it has gained traction...
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