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Tax Accrual Workpapers

Maine Court Declines to Follow Textron; Work Product Rule Protects Tax Accrual Work Papers

by Pierce Atwood LLP on

In a well-reasoned decision, Maine Superior Court Justice Michaela Murphy refused to grant the State Tax Assessor’s motion to compel deposition testimony relating to the taxpayer’s tax accrual (FIN 48) work papers and related...more

BP Canada: CRA Entitled to Tax Accrual Working Papers

by Dentons on

In BP Canada Energy Company v. Minister of National Revenue (2015 FC 714), the Minister brought an application pursuant to subsection 231.7(1) of the Income Tax Act (Canada) (the “Act”) before the Federal Court of...more

Focus on Tax Controversy & Litigation - July 2013

by Shearman & Sterling LLP on

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...more

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

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

by 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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