Focus on Tax Controversy and Litigation - May 2014


In this issue:

- Tax Court Rejects Partnerships’ Claim of Attorney-Client Privilege and Orders Release of Opinion Letters

- Litigation Heats Up in Section 1603 Cash Grant Program for Renewable Energy Projects

- Upcoming July FATCA Deadlines

- Taxpayer May Raise Reasonable Cause Defense to Excuse Late Payment Penalty

- Committee issued Updated Proposed Rule 37(e) on E-Discovery

- Credit Suisse Pleads Guilty and Agrees to Pay $2.6 Billion

- Wells Fargo Petitions Supreme Court to Review Economic Substance

- Excerpt from Tax Court Rejects Partnerships’ Claim of Attorney-Client Privilege and Orders Release of Opinion Letters:

On April 16, 2014, the Tax Court issued an opinion holding that two partnerships, AD Investment 2000 Fund LLC and AD Global 2000 Fund LLC, were required to release attorney opinion letters addressing “Son-of-BOSS” tax shelter transactions.

Please see full newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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