06/03/2019

Taxpayers Should Prepare For The Next Penalty Battleground

Taxpayers have several potential defenses to the accuracy-related penalty depending on the ground upon which the penalty is asserted, including “substantial authority,” “reasonable basis,” adequate disclosure,” “reasona

04/02/2019

OECD Global Minimum Tax Plan Faces Design Challenges

Other challenges include deciding how a minimum tax would interact with a “defensive regime” that denies deductions for payments made to an offshore entity that isn’t subject to the minimum tax regime, and how to avoid double taxation if