Includes bibliographical references and index. "#151673."
Contents:
Trial and appellate practice. Pre-audit planning, including document retention and spoliation -- Handling the international Examination -- Special document issues in international examinations -- IRS appeals and special appeals procedures -- The role of the competent authority : mutual agreement procedures -- Advance pricing agreements -- Exchange of information -- Post appeals litigation options and choice of forum -- Discovery in international tax cases -- Trial and appellate practice.
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