Under immense pressure to devise a fair and administrable solution for taxing digital businesses by 2020, the OECD yesterday released a public consultation document to test the waters with a potent
The U.S. Department of Justice (DOJ) continues to focus on cross-border investigations, leading to indictments of not only U.S. businessmen but also executives living abroad.
On October 11, 2019, the U.S. International Trade Commission (ITC) will begin accepting petitions for duty suspensions or reductions under the Miscellaneous Tariff Bill (MTB). Under the MTB, U.S.
In this article, George Hani and Colleen Brown, Senior Tax Advisor at Barrick Gold Corporation, discuss key changes to the "recalibrated" Compliance Assurance Process (CAP) announced by the IRS Lar
On November 20, 2018, the Internal Revenue Service's (IRS) Criminal Investigation Division (CI) issued a memorandum (the Updated Practice) providing significant guidance on voluntary disclosures (b
In this article, George Hani reviews the background and evolution of the Acknowledgement of Facts (AOF) Inf
In this article, George Hani analyzed how the partnership representative role has gr
In this article, Lauren Brig
The Internal Revenue Service (IRS) Large Business & International Division (LB&I) is transitioning to a centralized compliance and examination process that focuses on issue-based campaigns.
Over the past decade, the U.S.
The Bipartisan Budget Act of 2015 (the Act)1 that was signed into law on November 2, 2015, dramatically changes the rules for Internal Revenue Service (IRS) audits of partnerships and in
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