Protecting Tax Accrual Workpapers from the IRS
Insights on Taxpayer Confidentiality after the Textron Decision
Recording of a 100-minute CPE webinar with Q&A
Benefits
The panel will maximize your company's legal rights in these and other aspects of tax accrual workpapers:
- Work Product Protection: How to effectively argue that workpapers were prepared in advance of litigation, not in the ordinary course of business.
- Attorney-Client Privilege: How to show that tax counsel was providing legal advice, not merely giving an accounting review.
- Tax Practitioner Privilege: Circumstances under which your company's in-house tax staff's work qualifies as a legal review.
- Waiving Privileges: Where taxpayers must be careful of missteps that could force disclosure of otherwise protected workpapers.
Faculty
Norma J. Schrock
Executive Director, Tax Quality and Risk Management Group
Ernst & Young
She specializes in federal tax procedure and consults on the application of federal tax procedures to specific factual... | Read More
She specializes in federal tax procedure and consults on the application of federal tax procedures to specific factual circumstances. She assists in communicating current developments in tax policy and procedure to tax professionals. Prior to joining E&Y, she was with a major law firm and the Dept. of Justice, Tax Division.
CloseSusan Seabrook
Tax Partner
Latham & Watkins
She specializes in tax controversies and litigation and is active in the ABA Taxation Section. She formerly worked for... | Read More
She specializes in tax controversies and litigation and is active in the ABA Taxation Section. She formerly worked for the IRS in the District Counsel and National Chief Counsel Offices.
CloseElizabeth Askey
Partner
Pillsbury Winthrop Shaw Pittman
She specializes in complex tax controversies for multi-national corporations. Previously, Elizabeth was a director at... | Read More
She specializes in complex tax controversies for multi-national corporations. Previously, Elizabeth was a director at PricewaterhouseCoopers and a tax counsel with the Treasury Department.
CloseEdward L. Froelich
Of Counsel
Morrison & Foerster
He has represented corporations, partnerships, and individuals in the administrative and litigation stages of a federal... | Read More
He has represented corporations, partnerships, and individuals in the administrative and litigation stages of a federal tax controversy. He devotes substantial time to following developments in privilege and work product issues as they affect tax controversies, and is a frequent speaker on topics such as privilege, work product, FIN 48, and low-income taxpayer litigation issues.
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