The Pursuit of Transparency Does Not Trump the Work Product Privilege by ProQuest


In the past decade, the role of corporate tax executives has drastically changed, with executives are operating in an environment with more burdensome requirements and with greater demands for transparency by the financial statement auditors and the Internal Revenue Service. Today's environment is largely the result of the tax shelter initiatives by the IRS and other tax authorities alter the Enron collapse in 2001, the enactment of the Sarbanes-Oxley Act in 2002, and the issuance of FASB's Interpretation No. 48, Accounting for Uncertainty in Income Taxes, (FIN 48) in 2006. For all business enterprises that are subject to generally accepted accounting principles, FIN 48 provides rules for recognizing and measuring all tax positions that were previously taken in a filed tax return or that are expected to be taken in a future tax return. Taxpayers have been assessing the hazards of litigation for years and these assessments would not be done "but for" the risk of litigation.

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