Shearman And Sterling

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February 09, 2016

Focus on Tax Controversy and Litigation

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In addition to the discussion of the new partnership audit rules, this month’s issue features articles regarding a recent district court decision in Ellis v. United States regarding the attorney-client privilege and work product protections, amendments to the Federal Rules of Civil Procedure, recent developments concerning the IRS’s enforcement efforts regarding offshore accounts and a discussion of the benefits and potential pitfalls of making a tax deposit.

View full memo, Focus on Tax Controversy and Litigation