Where Do We Go From Here: A Comparison of Alternatives When You and the IRS Agree to Disagree
ABA Section of Taxation and Section of Real Property, Trust & Estate Law, Trust & Estate Division 2011 Joint Fall CLE Meeting
At the American Bar Association Section of Taxation and Section of Real Property, Trust & Estate Law, Trust & Estate Division Joint Fall CLE Meeting, Tax Chair William Sherman will moderate a panel titled "Planning for Foreign Person's Sales of Goods into the U.S.," and Tax Controversies and Litigation Co-Chair Jenny Johnson will speak on a panel titled "Where Do We Go From Here: A Comparison of Alternatives When You and the IRS Agree to Disagree."
Mr. Sherman's panel will address how, increasingly, consumer and commercial goods that are sold for use in the United States are manufactured outside of the U.S. The discussion will focus on structuring for foreign manufacturers and trading companies seeking to distribute goods into the U.S. without engaging in a U.S. trade or business or becoming subject to U.S. tax. Panelists will also discuss treaty and non-treaty issues, as well as state tax "traps for the unwary."
Ms. Johnson's panel will address options for taxpayers at the end of an unagreed examination, focusing primarily on IRS Appeals, alternative dispute resolution and litigation. Panelists will also discuss the advantages and disadvantages of the three litigation forums for tax disputes – the U.S. Tax Court, U.S. District Court and the Court of Federal Claims.