Cleaning Up After The Elephants – A Practical Reminder On Document Preservation Policies and Litigation Holds In Tax Disputes

By Phil Karter Any corporate tax executive who has ever been involved in contesting an audit adjustment knows all too well how unfavorable documents relating to the subject of the adjustment – particularly improvident comments reflected in email correspondences – can be an ongoing impediment to resolving a tax dispute from the audit phase right … More Cleaning Up After The Elephants – A Practical Reminder On Document Preservation Policies and Litigation Holds In Tax Disputes

Musings in the Aftermath of the First Schedule UTP Filing Season

By Phil Karter As reported earlier this week in the tax press, the recently completed initial filing season for Schedule UTP produced at least one major surprise in the eyes of IRS officials, who had anticipated a much greater number of items listed on the average Schedule UTP than actually materialized.  In fact, the IRS’s … More Musings in the Aftermath of the First Schedule UTP Filing Season

So It Begins: The Final Schedule UTP Is Out

By Jonathan Prokup The Internal Revenue Service on Friday released the final version of the much-anticipated Schedule UTP (and accompanying instructions) as well as additional guidance about changes that had been made the schedule.  At the same time, the IRS also announced an expansion of the Compliance Assurance Program (CAP) as well as some other … More So It Begins: The Final Schedule UTP Is Out

Speaking Alert: Work Product After Deloitte

Judging by the feedback we receive from our readers, the topic of workpapers and work product continues to be an area of major concern for many tax practitioners.  For those who are interested in learning more about the topic, particularly in light of the D.C. Circuit’s recent decision in United States v. Deloitte LLP, I … More Speaking Alert: Work Product After Deloitte

The Tax Workpapers Conundrum – Will “Justice” Kagan Accept What Solicitor General Kagan Opposed?

By Phil Karter In Tuesday’s confirmation hearings for Supreme Court nominee Elena Kagan, one topic on which there appeared to be agreement between the nominee and the panel was concern about the dwindling number of cases heard by the High Court. In response to questioning from Senator Arlen Specter, Kagan had no explanation for the … More The Tax Workpapers Conundrum – Will “Justice” Kagan Accept What Solicitor General Kagan Opposed?

The Workpaper Battle Continues: United States v. Deloitte LLP

By Jonathan Prokup Just when the Department of Justice must have thought that it could do no wrong in pursuing the workpapers of taxpayers and their auditors, it ran smack into the formidable blockade that is the Court of Appeals for the District of Columbia Circuit.  In United States v. Deloitte LLP et al., No. … More The Workpaper Battle Continues: United States v. Deloitte LLP