Insight

Insights on Tax Controversy & Dispute Resolution

News and insights on how to manage and mitigate controversy.

Tax disputes are on the rise due to a flurry of recent events. Learn more about related developments and insights from KPMG on how to manage and mitigate controversy.


Quarterly publication

Tax Controversy & Dispute Resolution Quarterly

This publication aggregates hot topics, uncovers dominant trends, and offers value-added insight from our TDR professionals.
 


Latest news

TaxNewsFlash - Tax Dispute Resolution

Reports of tax dispute resolution developments from around the globe involving income taxes, transfer pricing, indirect taxes, and other taxes.

 


Featured article

No Notice: Why Unilateral IRS Rulemaking Is Obsolete

The authors of this article focus on IRS rules carrying the force of law that were issued without any notice and comment procedures. (Tax Notes Federal - May 2, 2022)


Insights by tax topic

Federal

The Post-TCJA Interplay Between NOLs and Charitable Dedecutions
The authors of this article explore the complexities that corporations face (and the potential benefits they may enjoy) if they have charitable contributions and net operating loss carryovers available for deduction on their 2021 returns. (May 30, 2022)
No Notice: Why Unilateral IRS Rulemaking Is Obsolete
The authors of this article focus on IRS rules carrying the force of law that were issued without any notice and comment procedures. It also reviews court opinions addressing those rules and the Administrative Procedure Act and explains how taxpayers may use the opinions in future disputes. (May 2, 2022)

Global Disputes

The Basics of Managing Multilateral Controversy - Part 1
With multilateral controversies on the rise, it is important for taxpayers to understand how to effectively engage with tax authorities on these issues. Part 1 of this two-part article considers the context of these controversies and discusses the need for multilateral engagement by the tax authorities. (December 16, 2021)
The Basics of Managing Multilateral Controversy - Part 2
With multilateral controversies on the rise, it is important for taxpayers to understand how to effectively engage with tax authorities on these issues. Part 2 of this two-part article takes a deeper dive into procedures and takes a deeper dive into procedures and makes practical recommendations. (December 17, 21)
Managing Multilateral Controversy
Download PDF | Bloomberg Tax (November 5, 2021)
An ICAP Primer
Download PDF | Tax Notes International (August 23, 2021)
India Takes a Giant Leap With Faceless Audits
Download PDF | Tax Notes International (May 3, 2021)
ICAP: Taking disputes off the MAP
Download PDF | International Tax Review (April 1, 2021)
A U.S. Perspective on Transfer Pricing and EU State Aid
Download PDF | International Tax Review (October 1, 2020)
The State of Country-by-Country Reporting
Download PDF | Tax Notes International (August 31, 2020)
Advance Pricing Arrangement Series - Asia Pacific
Download PDF | Bloomberg Tax (May 5, 2020)
EU Mandatory Disclosure Impending for Certain Transfer Pricing Arrangements
Download PDF | International Tax Review (March 1, 2020)

Transfer Pricing

Tax Certainty: The March Goes On
The authors of this article review recent developments in 'tax certainty'. (January 2022)
Pillar One's Amount A: A Revolution in TP Controversy
Download PDF | International Tax Review (December 1, 2021)
IRS Memo Complicates Post-Altera Compliance
Download PDF | Tax Notes International (September 20, 2021)
IRS Memo Raises Issues for Post-Altera Stock-based Compensation True-ups
Download PDF | International Tax Review (September 16, 2021)
The Blocked Income Problem in Transfer Pricing
Download PDF | Tax Notes International (June 21, 2021)
MAP: Past, Present, and Future
Download PDF | Tax Notes International (April 12, 2021)
Off the MAP: Dispute Resolution in the BEPS 2.0 Blueprints
Download PDF | Tax Notes Federal (January 11, 2021)
Mark R. Martin

Mark R. Martin

Principal, Economic & Valuation Services, Washington National Tax, KPMG US

 

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