Following their recent announcement regarding new partnership and global high wealth enforcement initiatives, the Internal Revenue Service (IRS) on Oct. 20 announced another enforcement initiative focusing on foreign corporations and the largest corporate taxpayers. Last week, IRS Commissioner Danny Werfel announced the IRS would be sending out approximately 150 compliance alerts to U.S. subsidiaries of foreign corporations. 

Continue reading the full GT Alert.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Sharon Katz-Pearlman Sharon Katz-Pearlman

Sharon Katz-Pearlman focuses her practice on the representation of large multinationals, partnerships, and other taxpayers, before the IRS. She represents clients from the pre-exam phase (voluntary disclosures, pre-filing agreements) through examination, appeals, and into litigation if necessary. In addition, Sharon has represented clients

Sharon Katz-Pearlman focuses her practice on the representation of large multinationals, partnerships, and other taxpayers, before the IRS. She represents clients from the pre-exam phase (voluntary disclosures, pre-filing agreements) through examination, appeals, and into litigation if necessary. In addition, Sharon has represented clients using the full range of IRS Alternative Dispute Resolution techniques which are available to taxpayers, and advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs.

Sharon has deep experience with the Mutual Agreement Procedure (MAP) and the Advanced Pricing Agreement program (APA) working with Competent Authority to reach resolution on a variety of transfer pricing issues. She also consults with multinationals dealing with enforcement activity around the world, assisting them in developing practices and procedures which ensure consistency and a full understanding of the entity’s global disputes landscape. She consults frequently with clients on application to the OECD’s International Compliance Assurance Programme (ICAP) process.

Photo of Barbara T. Kaplan Barbara T. Kaplan

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals…

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.