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    D.C. Circuit Finds Work Product Protection Not Waived by Disclosure to Independent Auditors

    Article The D.C. Circuit denied an IRS motion to obtain documents in connection with ongoing tax litigation affirming in part a district court’s holding that a company did not waive work product protection when it disclosed certain documents to its auditor.
    Published on November 02, 2010

    MD&A Disclosures Relating to Financial Instruments

    Article In this column, I reveal why IFRS requires more extensive disclosures than any other accounting standard and then briefly provide the content of IFRS disclosures and focus on the disclosure related to financial instruments and their impacts when dealing with debt covenants.
    Published on January 28, 2011

    Analytical Procedures

    Publication A description of publications available on analytical procedures
    Published on June 19, 2013

    ODC Tax Liability and Audit Information Cannot Be Disclosed

    Article The Federal Circuit held that audit tests and related information of third-party taxpayers pertaining to the assessment of the ozone-depleting chemicals excise tax was return information not subject to disclosure under Sec. 6103...
    Published on March 18, 2013

    Current Developments in Partners and Partnerships

    Article This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, income allocations, and basis adjustments
    Published on February 04, 2014

    The Road to Transparency

    Article The IRS has more examination tools than ever to evaluate tax compliance, and, if Announcement 2010-9 is any indication, this trend is not likely to reverse.
    Published on January 28, 2011

    Risk Assessment and Internal Control Publications

    Publication A description of publications available on risk assessment and internal control.
    Published on September 19, 2013

    IRS Advisory Panel Urges Changes to Risk Assessment Protocols

    Article The IRS's Large Business & International Division is focusing on new ways to identify large businesses for examination. This item summarizes recent IRS Advisory Council recommendations on the factors the IRS should consider when risk assessing large business taxpayers.
    Published on May 31, 2014

    Details of IRS Expanded Policy of Restraint Not Yet in IRM Range of Applicability Unclear

    Article Though the IRS in 2010 expanded its policy of restraint in requesting audit and tax accrual workpapers, it has not yet updated the Internal Revenue Manual to reflect those changes
    Published on April 01, 2013

    Small and Medium Enterprises Should Consider Making Advance Pricing Agreements

    Article This item discusses the procedures that small and medium-size enterprises can use to obtain advance pricing agreements with the IRS so they can minimize their exposure to intercompany pricing adjustments on audit
    Published on October 05, 2010

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