Fenwick tax partner Julia Ushakova-Stein spoke on a panel for the International Tax Review’s Women in Tax – West Coast event and discussed how companies can turn to alternative dispute resolution tools—specifically mutual agreement procedures (MAPs)—in response to a predicted rise in tax disputes.
“Recently there was one MAP case resolved in the taxpayer’s favor and it took three years from submission to solution, and this might have been on the fast side,” said Ushakova-Stein. “If you’re filing a MAP case that would affect multiple jurisdictions, you could just file in the U.S.—but authorities tend to prefer filing in both jurisdictions to be able to speed up the case in some way, especially when the authorities are meeting, which is a few times a year.”
Ushakova-Stein emphasized that corporate taxpayers should prepare for audits while planning any complex transactions by anticipating questions and incorporating the individuals in charge of the relevant transactions: “Have in your file who is involved in that transaction internally and externally, because those are the people you are going to have to contact down the road.”
Read the full article on International Tax Review (subscription required).