JONES DAY PRESENTS®: The Shifting Global Tax Controversy Landscape

Niv Tadmore:

The global tax controversy landscape is evolving and it's polarizing. Geopolitical issues are unstable. Governments want and need more revenue and taxpayers are dealing with uncertain issues almost everywhere.

Lauren Moses:

There's more demand than ever on revenue authorities around the world to collect tax, and that's putting increased pressure on them and driving their activities.

Lou Berger:

The tax world is very complex and even is more complex today than it was like a decade ago.

Clients want to do the right thing, but it's not easy to do the right thing because the rules are complex and they are supposed to be coordinated, but in practice, tax authorities take their own perspective, they have different interpretations.

Rodrigo Gómez Ballina:

Tax authorities are also getting clever. They are getting more tools, more anti-abuse provisions.

Lori Hellkamp:

Increasingly, audits are across borders. Taxing authorities are sharing information, often automatically, and so there are no longer audits and exams and disputes purely in isolation.

Nicolas André:

Tax disputes tend to be more and more international. Routine audits starting in one jurisdiction can quickly span over several jurisdictions, or at least trigger questions and investigations in other jurisdictions.

Lauren Moses:

On top of uncertainty in the current position, it's uncertainty about what's happening in the future. How are tax managers managing their internal stakeholders? They need to manage their shareholders, their board, the CEO, all the people in the organization and outside of the organization that have an interest in the way that this company's operating. And that's a very difficult thing to do in an uncertain environment.

Niv Tadmore:

New issues are coming up, novel issues, issues that are uncharted waters for the clients, for us, and for the revenue authorities. And there is no playbook.

Lauren Moses:

When you're dealing with the tax authority, there's far more to managing that relationship than just going through a process to litigate a matter. You have to understand what drives them, and that's often more than the money.

Justin Campolieta:

The Jones Day Tax Controversy team, especially on the IRS side, is unparalleled. In terms of its experience with governments, we have three attorneys that have combined over 60 years of experience litigating cases on behalf of the IRS, virtually every single transfer pricing case in the United States in the past decade.

And that is valuable to clients, and it provides useful and unique insights into how the government works, why they try cases, what motivates them, and how you can resolve them.

Lori Hellkamp:

We work across our practice groups, so we're able to pull in the appropriate professionals and lean on our colleagues in other areas.

By seeing the bigger picture, we're able to help clients resolve issues in a way that is conscious of never resolving successfully an issue in one jurisdiction that actually creates an issue in another jurisdiction.

Lou Berger:

It benefits clients that we are everywhere and that we work well together. When we call someone in Asia, they will jump in it on the spot.

Lauren Moses:

So when a client picks up the phone and calls us with an issue, we can really tap into that global network and figure out who's the best person for the job.

Niv Tadmore:

We are a really true global partnership, which means we can focus on the real issue, which is the client's best interest.

Justin Campolieta:

We rise and fall together. And so, what's important is that we get the right people, get the right result, and truly provide service to our client.