Tag Archives: Reportable tax position

Attorney-client (tax) privilege needs a fresh look

In an article published in the New York Times the former Commissioner of the IRS in the US has hinted that the close relationship between lawyers/accountants and their corporate clients may have contributed in some measure to the financial crisis of 2008. He queries whether it would be prudent to ask whether lawyers and accountants offer the same protection against corporate misconduct that they once did. The article draws attention to some of the large corporations in America able to … Continue reading

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Reportable tax position schedule (RTP)- U.S model (FIN 48) in the making ?

The ATO has announced that it is developing a “Reportable Tax Position’” schedule to the 2012 company tax return. According to the ATO a reportable tax position is a position that has not been otherwise adequately disclosed to the Commissioner and is any of the following: A material position that is ‘not more likely to be correct than incorrect’ A position in respect of which uncertainty about taxes payable or recoverable is recognized and/or disclosed in the taxpayer’s or a … Continue reading

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