Not surprisingly, the words 'complicated' and 'uncertain' sum up how some taxpayers describe the current tax audit and controversy landscape in the United States. There are a myriad of factors that continuously shift and evolve, depending upon your perspective. The actions of taxpayers, the Internal Revenue Service, the courts, the Obama Administration, and the US Congress all weigh in. Also, international organizations in which the United States is a member, such as the Organisation for Economic Co-operation and Development and the United Nations, are becoming more and more influential with respect to tax policy. For multinational companies, tracking and managing this environment is exponentially more difficult because the tax audit and controversy trends and key issues in the United States often correlate with broader trends occurring on the global stage, requiring an understanding of the latter as well.
This Alert highlights a list of 10 'hotspots' – key issues and trends that are shaping the US tax audit and controversy environment for multinational companies.