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Tax Contingencies Articles

IRS Scales Back Its Draconian Schedule UTP Draft, And Requires The Finalized Schedule In 2010

September 17th, 2008

September 2010 On September 24, 2010, the IRS issued Announcement 2010-75. This covers final Form 1120, Schedule UTP (Uncertain Tax Positions Statement) and related instructions. [...]

Tax Accrual Workpapers Are Probably Safe From The IRS’s Probing Eyes

September 17th, 2007

To maintain accounting records under generally accepted accounting principles, companies need to assess the likelihood of judgmental positions being sustained. The recent tax case United [...]

IRS Loses Another Case Involving Auditor Work Papers

September 17th, 2007

  In Regions Financial Corp. v. United States, (N.D. Ala., No. 2:06-CV-00895-RDP, 5/8/08), the IRS lost another battle in its effort to get information from [...]

First Circuit Applies New Standard Restricting Work Product Privilege When Information Is Used For Financial Reporting

September 17th, 2007

The attorney work product doctrine, now codified in Federal Rule of Evidence 26(b)(3), protects from discovery documents prepared “in anticipation of litigation or for trial.” [...]

The FASB’s Gift To The IRS

January 16th, 2007

Updated January 2007   In June 2006, the Financial Accounting Standards Board (FASB) issued FIN 48, an amendment to existing standard no. 109, “Accounting for [...]