After the evidentiary record closes, the parties submit post-trial briefs and proposed findings of fact. These briefs address the legal framework, evaluate expert testimony, and connect the trial record to the governing regulations and treaty provisions.
The United States Tax Court issues three primary forms of opinions:
Where the court resolves the legal issues, but the precise tax liability must still be calculated, the parties submit computations under Tax Court Rule 155 before the final decision is entered.
Next, let’s understand the different stages of International tax litigation: pre-trial proceedings, trial, and post-trial proceedings. Each stage serves a different purpose in resolving disputes involving cross-border tax issues, evidence, and legal arguments.