Statutes of Limitation and International Taxes

By Andrew R. Roberson and Elizabeth Chao on March 8, 2018

Posted In IRS Audits, IRS Guidance, Tax Reform, Trial Courts, Uncategorized

In late 2017, we provided a brief overview of statutes of limitation in the international tax context. At that time, we noted a forthcoming article on the subject. We are pleased to report that our expanded article on the subject has been published in the January-February 2018 edition of the International Tax Journal. The full article can be viewed here.

Tags: Code Sec. 6501(a), Code Sec. 956, Form 5471, GILTI, global intangible low-taxed income, gross income exception, Internal Revenue Code, statute of limitations, Subpart F income

Andrew R. Roberson
Andrew (Andy) R. Roberson focuses his practice on tax controversy and litigation matters. He represents clients before the Internal Revenue Service (IRS) Examination Division and Appeals Office and has been involved in more than 50 matters at all levels of the federal court system, including the US Tax Court, several US courts of appeal and the Supreme Court. Andy has experience settling tax disputes through alternative dispute resolution procedures, including Fast Track Settlement and Post-Appeals Mediation, and in representing clients in Compliance Assurance Process (CAP) audits. He also represents individuals in Global High Wealth Industry Group audits and in connection with offshore disclosure programs. Read Andy Roberson's full bio.

Elizabeth Chao
Elizabeth Chao focuses her practice on US and international tax matters. Read Elizabeth Chao's full bio.

Statutes of Limitation and International Taxes

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