November 2009

Textron and the Near Certainty of Supreme Court Review

By Anthony M. Sabino

A new federal appeals court decision promises to give significant pause to corporate counsel, particularly in-house tax attorneys. To their dismay, the First Circuit has ruled that no amount of anticipation of litigation, nor the intimate involvement of legal counsel, can ever immunize so-called "tax accrual workpapers" from discovery by the IRS.

Subscribers: click here for the full story

Non-Subscribers: click here to subscribe

Pay per view ($20.00)