U.S. and Europe Tax Practice Trends

10:45 – 12:15 EDT / 15:45 – 17:15 CET

CONCURRENT SESSION 2
Fighting on Multiple Fronts: Cross-Border Disputes and Bilateral Resolution

In this panel we will discuss dispute prevention and dispute resolution mechanisms at the various stages of the tax administrative procedure.
We will start our panel with an up to date report from the IRS on MAP cases, in particular relating to transfer pricing topics, and an outlook on current projects on the domestic as well as the OECD level. The panel will then focus on case studies relevant to multiple jurisdictions, and will explore topics such as joint audits on the basis of the EU Administrative Assistance Directive, permanent establishments and the implementation of the EU Tax Dispute Resolution Directive, and challenging a GAAR in a MAP proceeding.

Co-Chairs

• Annette Keller, McDermott Will & Emery, Munich
• Sarah E. Paul, Eversheds Sutherland, New York, NY

Speakers

• Jennifer Best, Director, Treaty and Transfer Pricing Operations Practice Area, IRS,
  Washington, DC
• Dèlcia Capocasale, Cuatrecasas, Barcelona
• Raul-Angelo Papotti, Chiomenti, Milan
• Floran Ponce, Lenz & Staehelin, Geneva