International tax litigation typically unfolds in three main stages: pre-trial, trial, and post-trial. The process begins with fact development and procedural steps, moves to the presentation of evidence and arguments before the court, and concludes with decisions, appeals, or enforcement. Each stage plays a practical role in resolving complex cross-border tax disputes.
Next, let’s understand each stage one by one, which is generally applicable to all three courts, such as the U.S. Tax Court, U.S. District Court, and U.S. Court of Federal Claims: