*** Please note: This event is a rebroadcast of the LIVE event which was originally run on February 2, 2010. Speakers Scott Balestrier and Phillip A. Pillar will return for a live audience question and answer session.***
The surprising United States First Circuit Court of Appeals en banc opinion in Textron (U.S. v. Textron, Inc., No. 07-2631 Aug. 13, 2009) - which may go to the Supreme Court - has tax executives and their advisors wondering how they can keep their most sensitive tax analyses from disclosure to tax authorities. (http://www.journalofaccountancy.com/Web/20092045.html). In a stunning announcement made January 26, 2010, IRS Commissioner Shulman revealed a new proposed tax form to require certain business taxpayers to report all of their uncertain tax positions as part of their annual income tax returns. Meanwhile IRS will maintain its policy of "voluntary restraint" in requesting tax accrual work papers. But while IRS has this policy, other tax authorities - foreign, state and local - may not. During this 2-hour rebroadcast, you will hear a substantive discussion on this issue and answer your questions on the evolving rules and practices that you need to know to protect your strategies from discovery in a tax dispute.
Attending this rebroadcast will give you tools necessary to understand the risks to your sensitive tax analyses and how they may be protected.
Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Conference
Recommended CLE/CPE Hours: 2.0
Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.
Advance Preparation: Print and review course materials
Course Code: 103951
W. Scott Balestrier
Partner, Tax Services
Phillip A. Pillar
Shareholder
W. Scott Balestrier, Partner, Tax Services, BDO Seidman, LLP, and
Phillip A. Pillar, Shareholder, Greenberg Traurig, LLP
A recap of the stunning announcement by IRS Commissioner Shulman and the surprising appellate court reversal and U.S. v. Textron
- An experienced view of tax accrual workpapers after FIN 48 (now known as "ASC 740")
- An update of the IRS's policies on tax accrual workpapers and requests for them
- A first look at the proposed new tax form announced January 26, 2010
- An analysis of the potentially sensitive information in tax accrual workpapers using examples
- Strategies for protecting sensitive information from discovery by tax authorities after Textron
- Strategies for protecting sensitive information from discovery by tax authorities after the proposed new tax form.
- Tax Executives
- Tax Advisors/Directors
- In-House Counsel
- Outside Counsel
- Auditors
- Tax Attorneys/Consultants
This is a must attend event for anyone interested in hearing the latest discussion on this very timely issue on protecting your tax strategies.
- New guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A