July 16, 2014

Focus on Tax Controversy and Litigation


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In addition to a discussion of the Supreme Court’s recent decision in Clarke, this month’s issue features articles regarding the Southern District of New York’s decision in Schaeffler, which denied attorney-client privilege and work product protection to a tax memorandum circulated to a bank consortium, the IRS’s recent announcement to expand the OVDP streamlined program to include resident US taxpayers, developments in connection with OECD’s BEPS Action Plan, welcomed changes to Circular 230 covered opinion rules, and criminal sentencing of a former partner at Jenkens & Gilchrist in connection with tax shelter activities.

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