The BEPS Project, new risk assessment tools, CbCR requirements, and enhanced enforcement actions, among other challenges, are creating unprecedented levels of uncertainty for taxpayers, writes C David Swenson, global leader of PwC’s tax controversy and dispute resolution network.
Significant developments in the area of US tax controversies occurred in 2017. Andrew J Kim and Larissa B Neumann discuss some of the important US tax cases from this year, including several large § 482 transfer pricing cases.