Category

Tax Disputes

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In brief After initially granting certiorari and hearing oral arguments in In re Grand Jury ─ a matter concerning the application of the attorney-client privilege to dual-purpose communications ─ the United States Supreme Court “dismissed as improvidently granted” the case. Tax practitioners had hoped that a ruling by the Supreme Court would resolve a circuit split regarding the extent to which such communications fall within the ambit of the privilege. Background As a general rule, a lawyer’s…

In brief On 22 November 2022, the Organization for Economic Co-operation and Development (OECD) released the Mutual Agreement Procedure (MAP) statistics for 2021 (“MAP Statistics”). The 2021 MAP Statistics were produced pursuant to Base Erosion and Profit Shifting (BEPS) Action 14, which seeks to improve the resolution of tax-related disputes between jurisdictions. In Depth The MAP Statistics cover 127 jurisdictions in 2021 (up from 118 jurisdictions in 2020) and nearly all MAP cases worldwide, and…