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Recognition of Accountant-Client Privilege for Federal and State Tax Purposes

In light of recent cases, such as U.S. v. Textron, Inc. , 577 F. 3d 21 (1st Cir. 2009), cert. den. No. 09-750, May 24, 2010, and Comm. of Revenue v. Comcast Corporation & Continental Teleport, Inc., 453 Mass. 293; 901 N.E.2d 1185; 2009 Mass. LEXIS 31 (March 3, 2009), practitioners are faced with...

A.W. Fin. Servs., S.A. v. Empire Res., Inc., 981 A.2d 1114 (Del. 2009)

Tracking unclaimed property dormancy periods can present administrative problems for holders. Aside from reporting delinquency hazards that may follow a holder's failure to heed dormancy period limits, liability issues can emerge if the holder prematurely allows property to be escheated. Here, the...

Maryland Court Conflates Tax Principles; Rules Holding Companies Taxable

By Michele Borens and Jeffrey A. Friedman On November 9, 2010, the Maryland Tax Court issued another unfavorable decision against a taxpayer and upheld the Maryland Comptroller's assessment against out-of-state intangible holding companies. In W.L. Gore & Associates, Inc., Gore Enterprise...

Can Loopholes Blow the Whistle on Whistleblowers?

Two court actions in Wisconsin, one of them now before the Seventh Circuit, open a rare window into corporate tax compliance. These actions raise questions about IRS competence in audits and reveal big holes in federal laws to encourage and protect whistleblowers. In an unusual move the day before...

Supreme Court Resolves "Hot Button" Tax Issue - Holds Chevron Deference Applicable to "Interpretive" Regulations

By Jerome B. Libin On January 11, 2011, the U.S. Supreme Court unanimously upheld Treasury regulations interpreting the "service by a student" exclusion to the definition of "employment" for FICA purposes. Mayo Found. for Medical Education and Research v. United States , No. 09...

Mayo Intensifies Treasury Reg Authority

The U.S. Supreme Court's recent decision in Mayo Foundation for Medical Education and Research v. United States , 131 S. Ct. 704, 178 L. Ed. 2d 588, 2011 U.S. Lexis 609 (2011), provided guidance, after several decades of litigation, on the degree of deference afforded to agency rules in general and...