In this issue:

- District Court Protects Opinion Work Product Contained in Tax Accrual Workpapers in Wells Fargo

- IRS Restricts Private Letter Rulings for Spin-Offs and Other Corporate Nonrecognition Transactions

- Kearney Partners Tax Shelter Rulings Address Judicial Review of Penalty Assertions by the IRS and Privilege Questions

- Southern District of New York Permits SEC to Seek Disgorgement of Unpaid Taxes

- Swiss Parliament Rejects US Tax Deal

- US Seeks Identities of Wegelin’s Former American Clients

- Excerpt from: District Court Protects Opinion Work Product Contained in Tax Accrual Workpapers in Wells Fargo

The US District Court for the District of Minnesota granted in part and denied in part Wells Fargo’s petition to quash three summonses relating to tax accrual workpapers (“TAWs”) issued to Wells Fargo and its independent auditor, KPMG, after Wells Fargo refused to provide its TAWs for tax years 2007 and 2008.1 The government sought to obtain information regarding Wells Fargo’s financial reporting and uncertain tax positions (“UTPs”).

Please see full newsletter below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:

IRS
Tax

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.

© Shearman & Sterling LLP | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.
×
Loading...
×
×