Taxation International Taxation

Aggrieved Taxpayers Versus Tax Authorities

By Naoki Matsuda
Kluwer Law International May 2024

Specifications

ISBN-13
9789403522081
Publisher
Kluwer Law International
Publication
May 2024
Format
Hardback
Jurisdiction
International ? Countri(es) for reference only

Details

Aggrieved Taxpayers Versus Tax Authorities is an exceptionally handy, informative and insightful book that assesses the status of tax disputes of some representative countries and their historical and recent moves to attain a workable balance between the challenge of enhancing taxpayers’ access to justice and that of realizing speedier resolution of tax disputes. The countries highlighted are Japan, the United States (U.S.), the United Kingdom, Australia, and New Zealand, with the European Union represented by Ireland and the Netherlands, from all of which the author makes comparisons of their rules and practices affecting the status of tax disputes and their resolution.

 

What’s in this book:

In this book, the author discerns key common factors that significantly work toward increasing or decreasing the number of tax disputes in a country: 

 

  • tax structure;
  • tax audit;
  • compliance level;
  • modes of tax dispute settlement;
  • level of taxpayers’ burden;
  • power and performance of reviewing bodies;
  • complementary administrative and legal measures for taxpayers; and
  • requirement for and effect of filing tax objections/litigations.

 

After summarizing how those factors work in those countries, the final chapter outlines reform options to strike a workable balance between the two challenges.

 

How this will help you:

In its extraction/analysis of highly disputed themes (e.g., in the case of the U.S., penalties, collection due process, innocent spouse relief, gross income, trade or business expenses), its identification of key factors that affect the number of tax disputes, and its cross-country comparison of how those factors are at work in tax law, procedures governing tax objections/litigations, etc., this trailblazing book delves deep into the issue of how some types of tax provisions are disputed more frequently than others. It will be highly appreciated by tax professionals and tax authorities in pursuing fairness and speedy resolution of tax disputes.

Table of Contents

List of Abbreviations

 

Prologue

 

Executive Summary

 

CHAPTER 1

Status in Japan

 

CHAPTER 2

Status in the United States

 

CHAPTER 3

Status in the United Kingdom

 

CHAPTER 4

Status of Commonwealth Countries (Australia and NZ)

 

CHAPTER 5

Status of EU Member States (Ireland and Netherlands)

 

CHAPTER 6

International Comparison and Options for Reform

 

Epilogue

 

Appendix Attachment: Tax Tribunal’s Decisions Published on Its HP (2,594 as of 8/9/2022) as Summarized and Translated in English by the Author

 

Bibliography (in Order of Citation)

 

Table of List of Decisions/Rulings (in Chronological Order)

 

Index

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