Recent Case Highlights Convergence of Substance and Procedure in International Tax Disputes




Globalization is triggering more tax disputes with the IRS, and winning such clashes requires knowledge of both substantive international tax law and complicated procedures. A good example is Mattson v. United States. That case involves U.S. citizens working overseas, claims for special tax benefits for expatriates, the effect of Closing Agreements, novel interpretations of treaties, refund actions and procedural twists. Using Mattson as a starting point, this article shows how international tax and tax procedure often converge in modern battles with the IRS.


About Hale E. Sheppard

HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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