According to the DoJ, a Canadian man who led a multi-million dollar tax fraud conspiracy was sentenced on August 28, 2018 to 60 months in prison. According to documents filed with the court and evidence introduced at a related trial, Daveanan Sookdeo, 46, formerly of Ontario, Canada, promoted a scheme in which Canadian citizens filed false tax…
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Transnational Database Exchange Triggers Transfer Pricing Audits
According to Margaret Kent, TransferPricingConsortium.com & Robert Feinschreiber, Charles River Associates, until now, tax administrations had lacked sufficient databases to undertake comprehensive country-by-country transfer pricing audits. Now, as of end of June 2018, tax administrations are ready to begin these audits and assessments in earnest against MNCs. The transfer pricing implementation rules cast a long shadow –…
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Understanding IRS Tax Audits – Part II
On July 24, 2018 we posted Understanding IRS Tax Audits - Part I where we discussed that careful advance preparation can help reduce the scope of a tax audit or examination and can lead to a more favorable outcome. Although a thorough understanding of the underlying facts and applicable law is a must, understanding IRS procedures…
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DC Rejects Challenge to Mutual Collection Process in U.S./Canada Treaty
A district court in Retfalvi v. U.S. (DC NC 8/15/2018) 122 AFTR 2d ¶2018-5144 , granted the government's motion to dismissed a taxpayer's refund suit for failure to state a claim where the taxpayer paid and then sought to recover from IRS an amount he paid based on his Canadian tax liability and Canada's collection assistance request…
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