Last week was a good one for the IRS, and not so good for those trying to avoid IRS scrutiny. The agency made big headlines when it finally got UBS to turn over the names of certain U.S. individuals who tried to evade taxes by using foreign accounts. In a less heralded, but potentially significant development, the IRS on Thursday won a ruling by the 1st U.S. Circuit Court of Appeals in U.S. v. Textron (pdf) that may give it much greater access to internal materials prepared by corporate taxpayers.
As Larry Hill of Dewey & LeBoeuf told The Wall Street Journal‘s Law Blog: “It’s a landmark decision that will cause tax directors of public companies to toss and turn in their sleep and will encourage the IRS to be more aggressive in seeking tax accrual work papers.”
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