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Disclosure Requirements Summons

Eversheds Sutherland (US) LLP

U.S. District Court Orders Disclosure of Tax Accrual Workpapers, but Protects Opinion Work Product Information

On June 4, 2013, the U.S. District Court for the District of Minnesota held that certain information contained in tax accrual workpapers must be disclosed by the taxpayer pursuant to an Internal Revenue Service (IRS) summons,...more

McDermott Will & Emery

IRS Denied Peek Behind the Curtain: District Court Protects Wells Fargo’s Tax Accrual Workpapers

McDermott Will & Emery on

In an important taxpayer victory, a Minnesota District Court ruled in favor of Wells Fargo, holding that the measurement and analysis of its uncertain tax positions was protected from disclosure by the work product privilege....more

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