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No Notice: Why Unilateral IRS Rulemaking Is Obsolete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 topic

COVID-19

Federal

No Notice: Why Unilateral IRS Rulemaking Is Obsolete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.
Underpayment Interest and the "Use of Money" Argument - Again
The author examines how credit-elect overpayments are treated when there are subsequent tax assessments.
IRS Launches Large Partnership Audits
Download PDF | Bloomberg Tax (November 17, 2021)
Clarity Provided for Timing of Revenue Under the Accrual Method
Download PDF | Tax Notes Federal (October 7, 2019)
CAP Updates Bring Transfer Pricing Issues to the Fore
Download PDF | Tax Notes Federal (July 22, 2019)
The IRA and the APA: Denial Is Not a Strategy
Download PDF | Tax Notes (January 8, 2018)

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.
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.
Managing Multilateral Controversy
Download PDF | Bloomberg Tax (November 5, 2021)
U.S. Tax Court Finds Limits to Treat-Based Double Tax Relief
Download PDF | International Tax Review (September, 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)
The Evolution and Future of the Mutual Agreement Procedure
Download PDF | Tax Notes International (December 2, 2019)
Advance Pricing Arrangement Series - Europe
Download PDF | Bloomberg Tax (September 3, 2019)
The U.S. MAP-APA Insights Series: China
Download PDF | Tax Notes International (June 10, 2019)
The IRA and the APA: Denial Is Not a Strategy
Download PDF | Tax Notes (January 8, 2018)

Transfer Pricing

Tax Certainty: The March Goes On
The authors of this article review recent developments in 'tax certainty'.
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)
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)
A New Era for Secondary Transfer Pricing Adjustments?
Download PDF | Tax Notes Federal (August 24, 2020)
COVID-19 and Dislocated Employees: DEMPE and Risk Control Considerations
Download PDF | International Tax Review (June 1, 2020)
Advance Pricing Arrangement Series - Asia Pacific
Download PDF | Bloomberg Tax (May 5, 2020)
IRS Issues APA Statistics for 2019
Download PDF | International Tax Review (May 1, 2020)
EU Mandatory Disclosure Impending for Certain Transfer Pricing Arrangements
Download PDF | International Tax Review (March 1, 2020)
A New Era of Risk-based IRS Transfer Pricing Enforcement
Download PDF | Tax Notes International (March 30, 2020)
The Evolution and Future of the Mutual Agreement Procedure
Download PDF | Tax Notes International (December 2, 2019)
Advance Pricing Arrangement Series - Europe
Download PDF | Bloomberg Tax (September 3, 2019)
CAP Updates Bring Transfer Pricing Issues to the Fore
Download PDF | Tax Notes Federal (July 22, 2019)
The U.S. MAP-APA Insights Series: China
Download PDF | Tax Notes International (June 10, 2019)
Sharon Katz-Pearlman

Sharon Katz-Pearlman

Co-Principal in Charge, Tax Controversy & Dispute Resolution, KPMG US

Mark R. Martin

Mark R. Martin

Co-Principal in Charge, Tax Controversy & Dispute Resolution, KPMG US