Focus on Tax Controversy and Litigation - July 2014

In this issue:

- Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing

- Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine

- Streamlined OVDP Expanded to Resident US Taxpayers

- OECD Moves Forward on BEPS Action Plan

- IRS Issues New Circular 230 Regulations

- Former Jenkens & Gilchrist Partner Paul Daugerdas sentenced to 15 years in Prison

- Excerpt from Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing:

On June 19, 2014, the United States Supreme Court held that a taxpayer has a right to examine IRS officials regarding their purpose of issuing a summons.1 However, in reversing and vacating an Eleventh Circuit’s decision, the Supreme Court did not recognize a taxpayer’s right to a formal hearing based on unsupported allegations that the summons was issued in bad faith. The Supreme Court found that the Eleventh Circuit erred in ruling that a bare allegation of improper purpose was sufficient to question IRS officials and remanded the case to the circuit court for further consideration in light of the Supreme Court’s decision.

Please see full newsletter below for more information.

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Shearman & Sterling LLP on:

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