TAX INTERNAL REVENUE SERVICE PRACTICE AND PROCEDURE DESKBOOK
Thomas Greenaway ( KPMG LLP ) and Edward M . Robbins , Jr . ( Hochman Salkin Toscher Perez , PC )
This Deskbook offers tax lawyers , accountants , and tax professionals an all-inclusive guide into the knowledge and tactics necessary to represent clients effectively before the IRS . It was prepared by two leading tax controversy litigators who have guided numerous taxpayers through IRS examinations , appeals , and post-appeals dispute resolution . Organized in a way that ’ s helpful for readers who are wellversed in or new to IRS procedures , this book offers detailed practice pointers and Tax Court case law discussions . Readers can also consult a chart that neatly summarizes the numerous complex civil penalties the Internal Revenue Code allows .
Stay ahead of IRS rule and tax law changes with PLI ’ s Upkeep Service .
3 softbound volumes or digital , 2,844 pages , $ 525 , Item # 370683 , ISBN 978-1-4024-4431-9 , Updated annually or as needed
CONTENTS
VOLUME 1 1 Organization of the IRS 2 Circular 230 and the Ethics of Tax Practice 3 Types and Uses of Authority in Federal Tax Practice 4 Tax Returns and Interest 5 Taxpayer Access to IRS Information 6 The Examination Function 7 Large Case Examinations 8 Claims for Refund and Refund Suits 9 Administrative Appeal
VOLUME 2 |
10 |
Tax Court Litigation |
11 |
Statute of Limitations / Assessments / Summary Assessments |
12 |
TEFRA and the BBA |
13 |
Third-Party Liability |
14 |
Summons Power and Third-Party Contacts |
15 |
Major Civil Penalties |
VOLUME 3 |
16 |
Civil and Criminal Tax Fraud |
17 |
The Collection Process |
18 |
Recovering Attorney Fees : Section 7430 of the Code and Related Matters |
Table of Authorities Index
INTERNATIONAL TAX CONTROVERSIES A PRACTICAL GUIDE
Philip R . West , Amanda Pedvin Varma , Matthew Frank , and Steve Dixon ( Steptoe & Johnson LLP )
Compiled by an adjunct professor and a trio of prominent tax practitioners with substantial private and government practice experience , this resource offers readers a step-by-step guide on confronting U . S . tax audits that involve international assets and transactions . Its approaches are helpful for any tax practitioner , accounting professional , or high-net-worth individual . It is also instructive for anyone who works with or manages global wealth portfolios .
Readers will learn about the vital ingredients that go into successfully overcoming an international audit from the IRS and non-U . S . tax authorities . The treatise raises tips for retaining proper transaction paperwork , navigating international examination requirements , and more .
Stay on top of international tax developments with PLI ’ s Upkeep Service .
1 softbound volume , 408 pages , $ 315 , Item # 346332 , ISBN 978-1-4024-4112-7 , Published as needed
CONTENTS
PART I : INTERNATIONAL TAX AUDITS AND APPEALS 1 Early Preparation and Documentation for Audit and
Controversy 2 Pre-Audit Planning , Including Document Retention and
Spoliation 3 Handling the International Examination 4 Special Document Issues in International Examinations 5 IRS Appeals and Special Appeals Procedures
PART II : GOVERNMENT-TO-GOVERNMENT COOPERATION 6 The Role of the Competent Authority :
Mutual Agreement Procedures 7 Advance Pricing Agreements 8 Exchange of Information
PART III : LITIGATING INTERNATIONAL TAX CASES 9 Post-Appeals Litigation Options and Choice of Forum 10 Discovery in International Tax Cases 11 Trial and Appellate Practice
Index
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