Supply chain disruptions arising from the COVID-19 pandemic have led to challenges in business operations globally. Businesses are experiencing significant financial impacts from a myriad of issues, ranging from increased costs related to supply disruptions and manufacturing idle capacity, to unintended carrying cost of inventory stuck in transit, and loss of revenues due to disruption of sales channels. Loss reporting and increased expenses resulting from managing these issues are expected to result in increased tax controversy as tax administrations scrutinize who should bear these costs and assume these business risks. Disputes are also expected around the characterization and deductibility of payments,...