Law360, New York (November 21, 2013, 8:18 PM EST) -- Cross-border business structures are coming under increasing and intense scrutiny, especially in relation to the structure and management of their tax affairs. In conducting reviews of a U.S. taxpayer's affairs, or as part of proceeding to litigation, the Internal Revenue Service may want access to information that is located outside the U.S. In this article, we look at how the IRS can obtain U.K.-located information that is relevant to a U.S. taxpayer.
The Tax Treaty and OECD Convention
The U.S./U.K. Double Tax Treaty and the Organization...
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