International tax disputes in the United States generally proceed through a structured sequence of stages, from initial pleadings through final judgment and appeal. Generally, these procedural rules vary across different forums such as the Tax Court, the Court of Federal Claims, and U.S. District Courts. However, the overall progression is broadly similar.
International tax issues often require additional evidentiary and treaty-related considerations at each stage.
Next, let’s understand the different stages of an international tax litigation.