Tax Contingencies

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IRS Confirms Continued Partial Deductibility of Business Meals

October 2018 For months, the American Institute of CPAs (AICPA) and American businesses have been requesting guidance from the U.S. Treasury Department and Internal Revenue Service ("IRS") regarding changes made by the Tax Cuts and Jobs Act (TCJA) (Pub. L. No. 115-97).  These changes disallowed the deductibility of entertainment, amusement, recreation and qualified transportation fringe expenses beginning [...]

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

September 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 States vs. Textron, No. 06-198T (Aug. 29, 2007), is important in establishing a taxpayer’s right to prevent disclosure of (i) its internal analyses of these controversial tax positions, [...]

IRS Loses Another Case Involving Auditor Work Papers

September 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 outside accountants’ tax accrual work papers. This case could be particularly damaging to the IRS’s position because the Court’s rationale arguably would apply regardless of which split in authority [...]

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