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Tax Accrual Workpapers in the Aftermath of Textron
A Live Audio Seminar from CCH
Tuesday, October 30, 2007 - 1 PM Eastern; Noon Central; 10 AM Pacific
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
Invite Colleagues, Customers, Prospects and Business Referral Sources to Join You!
Learn What Textron Means to Corporate Tax Pros, Advisors, and Tax Accrual Workpapers
In late August, the federal district court handed the IRS a stunning defeat regarding the enforcement of a summons to inspect tax accrual workpapers. The court in Textron held that the work product privilege, which protects materials prepared or gathered by an attorney in anticipation of possible litigation or preparation for trial, applied and was not waived. It ruled that disclosure to Textron's independent auditor was not inconsistent with keeping the workpapers confidential and that the opinions of counsel contained in the workpapers were not information needed by the IRS to determine tax liability.
On Tuesday, October 30, CCH will host a two-hour audio seminar providing a practical review of the basic rules on attorney-client, accountant-client and work product protections, and the IRS policy on these matters. Presented by noted tax practitioners and commentators, Michael G. Goller, J.D. and Harvey Coustan, CPA, "Tax Accrual Workpapers in the Aftermath of Textron" will examine the recent Textron case, and its impact and lessons learned on protection of accrual review workpapers, including FIN 48.
All accountants and attorneys who advise clients on tax matters, as well as corporate tax, finance and legal directors and managers, will benefit from this hot topic seminar. The presentation time will include ample opportunity for you to ask questions your most pressing questions to Mr. Goller and Mr. Coustan.
Program Topics
The program will include explanation and analysis on:
- Protecting accrual workpapers—IRS Manual provisions, AICPA audit standards, and FIN 48
- Attorney-client and accountant-client privilege
- Work product protection
- Textron case
Learning Objectives
- Understand the basic rules on attorney-client, accountant-client and work product protections
- Obtain a practical understanding of federal district court’s analysis and decision to deny the IRS access to tax accrual workpapers in Textron
- Identify best practices for clients and advisors related to accrual workpapers to achieve work product protection
Register today for this insightful program on Tuesday, October 30 at 1 PM Eastern, Noon Central; 10 AM Pacific.
SPECIAL BONUS—each registered site will also get a free issue of CCH’s Journal of Tax Practice and Procedure
About the Speakers:
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Michael G. Goller, J.D. is a shareholder with the law firm, Reinhart Boerner Van Deuren s.c. in Milwaukee, Wisconsin. He focuses on tax controversy and tax litigation, as well as tax planning for clients ranging from large public corporations to mid-sized, privately-held businesses and their owners.
Michael works on behalf of his clients in disputes with the IRS, Department of Justice and various other taxing authorities. An experienced tax attorney and tax litigator, Michael helps his clients navigate the challenges of complex federal and state tax audits, disputes, administrative appeals, trials, and subsequent appeals. He has an impressive track record of both trying cases and negotiating favorable settlements for his clients before trial.
Michael regularly shares and deepens his expertise as a tax litigator through professional speaking and writing. He frequently speaks to professional and business audiences and organizations on issues of tax controversy, tax litigation and tax planning. Michael is a faculty member at the University of Wisconsin Milwaukee's School of Business where he teaches Tax Practice and Procedure in the Graduate Tax Program, and he has authored a number of significant articles and publications, including CCH’s Federal Tax Practice and Procedure Course. |
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Harvey Coustan, CPA is a consultant with the National Tax Office of RSM McGladrey, specializing in technical, procedural, and organizational matters. He retired as a partner from Ernst & Young in 1998, where he held several leadership positions, including partner in charge of the firm’s National Tax Practice in Washington, D.C.
He has spoken at numerous conferences, and his articles have appeared in several professional publications, including CCH’s Journal of Tax Practice and Procedure and TAXES: The Tax Magazine. He is a co-chair of the AICPA’s Tax Shelter Issues Task Force, has chaired the AICPA and Illinois CPA Society Tax Executive Committees, and has served on both the AICPA and Illinois CPA Society Boards of Directors. Harvey has also served on the Commissioner of Internal Revenue's Advisory Committee and on the JJ Pickle House Ways and Means Committee Task Force on Civil Tax Penalties.
He is a member of the National Conference of Lawyers and CPAs, and he has served as an assistant professor at DePaul University, an adjunct faculty member at Northwestern University Kellogg Graduate School of Management, and a Professorial Lecturer at Georgetown University. |
How the Audio Seminar Works
CCH’s live audio seminars require nothing more than a telephone connection. For the single per-site fee, you can have an unlimited number of listeners at your site participate, get up to speed and in-the-know on important topics, and get special bonus publications included with the seminar. Handout materials are provided in PDF format that you can download and copy for all those who will participate in the seminar at your location.
Practice Development Tip! Invite colleagues, business referral sources, clients and prospects to your office to listen in and participate on this seminar with you. They’ll appreciate your invitation to hear directly about this important topic.
Visit CCHGroup.com/AudioSeminars for more audio seminar topics, dates and times!
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Earn CPE Credit
- Two hours of CPE credit are available for an additional $25 per person wishing to receive a CPE certificate for their participation
- Course Level: Intermediate
- NASBA Field of Study: Taxes
- Prerequisites: Basic knowledge of federal tax practice and procedure
- Learn More About CCH's NASBA Registration
Special Bonus
Firms registering for this audio seminar will receive as a bonus the following publication:
Order CD Recordings of CCH Audio Seminars
If you are unable to attend this upcoming event and would like to order a recording—or if you would like to order recordings of past CCH Audio Seminars, please visit the CCH Audio Seminar Archive Library today.
Pricing:
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Site License: $249 – Registration includes one telephone connection at one location, one master set of handouts (with permission to make additional copies for the participants at your location), an unlimited number of people in one listening room can participate, and one seminar bonus publication per registered site. ($25 CPE fee additional for each person wishing to receive a CPE certificate for their participation.)
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CD Recording: $249 – The CD includes an audio recording of the event and handout materials in PDF format. Includes copy of seminar bonus publication with purchase. Available one week after the live audio seminar event. (Note: CPE credit is not available for the CD version of the presentation.)
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Site License and CD Recording Package: $349 – This specially-priced package provides you with the Site License access to the live audio seminar event AND the CD Recording.
Our Guarantee
If for any reason you are not completely satisfied with this program, we will provide a full refund - no questions asked!
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
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