MAP Quest: A Conversation with Doug O'Donnell on Cross-Border Dispute Resolution

09.03.2025 | Duration: 32:21

How does the Mutual Agreement Procedure (MAP) process work to resolve cross-border double taxation disputes, and in what ways have recent developments influenced the negotiation and resolution of MAP cases?

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Podcast overview

The Mutual Agreement Procedure (MAP) is a central process for resolving double taxation disputes between countries, particularly those arising from transfer pricing adjustments. In this episode, we explore how the MAP process functions at the IRS and internationally. What steps must taxpayers follow and how long does the process take? How are MAP cases negotiated between the IRS and foreign tax authorities? In general, how successful is MAP? What practical challenges and recent trends impact the effectiveness of the MAP process? And what are some alternatives to MAP available to taxpayers to resolve their cross-border disputes? 

Join us as our hosts Gary Scanlon and Kristen Gamboa interview Doug O’Donnell, formerly IRS Acting Commissioner and previously a participant in the OECD Forum on Tax Administration, to answer these questions and more on the latest episode of Inside International Tax.

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