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

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."


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