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Bloomberg Quotes Dianne Mehany on Cross-Border Tax Disputes Project

June 6, 2018, Bloomberg Law, Daily Tax Report

The IRS and seven other tax administrations, as well as eight multinational companies, will gather in July for a midpoint evaluation of the International Compliance Assurance Program (ICAP), a pilot project designed to limit cross-border disputes.

The basis for the “very important meeting” is to evaluate the process of the pilot program thus far, see where improvements can be made, and compare notes on streamlining the program for a larger roll-out, Douglas O'Donnell, commissioner at the IRS's Large Business and International (LB&I) Division, said June 4 at the 2018 OECD International Tax Conference. But multinationals are also concerned that no consensus has been reached regarding what constitutes high and low tax risks.

. . .

High Versus Low

Under these initiatives, a concern shared by taxpayers is that the definition of low-risk versus high-risk remains unclear, Dianne Mehany, a member at Caplin & Drysdale, Chartered, said.

“Is it a complexity that tends toward high-risk? Is it just your number of countries in which you're present?” Mehany said. “That's something that we would like more direction on.”

For the full article, please visit Bloomberg’s website (subscription required).

Excerpt taken from the article “Cross-Border Tax Disputes Project to Undergo Global Review” by Sony Kassam for Bloomberg Law, Daily Tax Report: International.


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