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.