Home      Login


Evaluating and Leveraging Alternative Dispute Resolution Options in Tax Disputes Involving Financial Institutions  


Author:  Todd  Welty.; Mark  Thomas.; Denise  Mudigere.


Source: Volume 25, Number 05, May/June 2012 , pp.25-34(10)




Journal of Taxation and Regulation of Financial Institutions

< previous article |next article > |return to table of contents

Abstract: 

Financial institutions operate in an increasingly complex and compliance-driven environment with ever greater governmental demands for transparency in their tax filings. This is a recipe for more numerous, significant, and perhaps unpredictable tax controversies at a time when certainty is a most precious commodity. While litigating a tax controversy is sometimes necessary, litigation is an expensive, lengthy, and often public process . Financial institutions should therefore be aware of and carefully consider the more significant alternative dispute resolution (ADR) tools. This article overviews and analyzes available ADR options, and suggests ways to leverage them so as to produce the most favorable outcomes.

Keywords: alternative dispute resolution; ADR; tax controversies; pre-filing agreements; advance pricing agreements; compliance assurance program; coordinated industry case program

Affiliations:  1: SNR Denton; 2: SNR Denton; 3: SNR Denton.

Subscribers click here to open full text in PDF.
Non-subscribers click here to purchase this article. $25

< previous article |next article > |return to table of contents