A Ray of Hope Amid International Tax Disputes



In Depth

Cym Lowell and Todd Welty wrote this bylined article on a new approach for addressing tax disputes that affect the tax planning structures of multinational enterprises (MNEs). The authors recommended that “the only realistic antidote” for current disputes “may be to create a dependable and independent treaty-based international tax dispute resolution process (ITDRP) designed to accommodate the needs of all stakeholders,” whether MNEs or taxing authorities.