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”).

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