The IRS’ Advance Pricing and Mutual Agreement-administered programs provide powerful tools that taxpayers can benefit from, but the programs do have limitations. Partner David Farhat and associate Mayowa Olujohungbe coauthored this article explaining how tax authorities can and why they should address base erosion and antiabuse tax liability that may arise from taxpayers’ use of these programs.
Competent Authority Resolutions and the Creation of BEAT Liability
Tax Notes International