In addition to a discussion of the Supreme Court’s decision in Woods v. Commissioner, this month’s issue features articles about a pair of recent decisions from the Southern District of New York regarding waiver of attorney client communications by disclosure to the SEC, two directives recently issued by the Internal Revenue Service’s Large Business & International Division regarding Information Document Requests, new John Doe summonses issued to US banks for the production of records about US taxpayers with offshore accounts, Notice 2013 69, which provides guidance on the implementation of FATCA for Foreign Financial Institutions, and an urge by Congress to seek extradition of Swiss residents charged with tax evasion offenses.View newsletter, Focus on Tax Controversy and Litigation
