We use cookies to provide you with the best possible experience. By using Orbitax's services, you agree that we may store cookies on your device. Cookie Policy.
The AI assistant for tax questions
Track worldwide tax law changes daily
Cross-border tax analysis and data
Unify and empower your entity management
Provides compliance steps, forms & rates
Visualize and manage your entity data
Comprehensive compliance management
Audit and global tax controversy tracking
Manage reportable cross-border arrangements
Country-by-country reporting & compliance
Pillar 2 planning, reporting and compliance
Calculate US tax impact of foreign operations
Automated workflows for recurring tax tasks
Secure API connections to 3rd-party systems
Secure storage for your tax documentation
The AI assistant for tax questions
Collaborate securely on your tax data
Share This Article
|
|
The key feature of the new MOU is the establishment of an independent review process whereby a factual disagreement in a MAP case must be referred to an Appeals Review Panel (ARP) for resolution. The ARP will be comprised of officials chosen by the IRS Chief of Appeals and the CRA Assistant Commissioner of Appeals. The MOU sets out the time frame for referring a case to the independent review process, the procedure for making and acknowledging the referral, the process for selecting the members of the ARP, rules regarding ex parte contacts, rules regarding meetings of the ARP, the...