Skip to Main Content
 

Tax Analysts' Worldwide Tax Daily Quotes Patricia Lewis: Proposed U.S. Competent Authority Procedures Could Complicate Issue Resolution

February 13, 2014, Tax Notes

Tax Analysts' Worldwide Tax Daily quoted Patricia Gimbel Lewis concerning the IRS's proposed expansion of the role of the U.S. competent authority and how the provision will affect taxpayers attempting to resolve U.S.-initiated transfer pricing issues. For the complete article, please visit Tax Analysts' website (subscription required).

Excerpt taken from the article "Proposed U.S. Competent Authority Procedures Could Complicate Issue Resolution" by Kristen A. Parillo for Worldwide Tax Daily.

Patricia Gimbel Lewis of Caplin & Drysdale asked about a provision that would limit taxpayers' ability to pursue cases with the IRS Office of Appeals. Under the proposed revenue procedures, taxpayers would have to choose whether to seek sole competent authority assistance or co-involvement of Appeals (via the simultaneous appeals procedure) within 30 days of the first conference with Appeals.

Lewis said that provision puts pressure on the first Appeals conference. "Often from taxpayers' perspective, they might think the field has made a crazy adjustment and figure when they get to Appeals everything will get sorted and the issue will go away," she said. "Very few cases of any kind go away at the first Appeals conference. The way this is now structured, if a transfer pricing or other issue of that sort doesn't go away at the first Appeals conference, taxpayers are going to have to make some hard decisions."

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at www.caplindrysdale.com.
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
202.862.5000
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2019 Caplin & Drysdale, Chartered
All Rights Reserved.