Tax controversy lawyers with Norton Rose Fulbright around the globe have prepared a fifth annual survey of certain tax controversy procedures and issues referenced below for Australia, Canada, France, Germany, Luxembourg, the Netherlands, South Africa, the United Kingdom and the United States.
While each tax controversy will involve unique circumstances, this survey serves as a reference tool for tax executives at multinational companies. It will be an evolving tool, and we plan to add additional countries in future surveys.
This edition covers the following procedures and issues:
- Collection of information
- Dispute resolution – administrative
- Transfer pricing
- Civil and criminal penalties
- Judicial challenges
- Privilege protection for information
- Statutes of limitations
- Reconciliation of laws/application of doctrines
2019 guide to Foreign Private Issuer status
A company organized outside the US subject to provisions of the US federal securities laws receives benefits if it qualifies as an FPI.