Section 6103 requires that the IRS keep taxpayers’ returns and return information confidential. But although intended to protect taxpayers, the statute contains a litany of exceptions, which, in practice, gives the IRS considerable flexibility. It has wide latitude to share taxpayer information within the Treasury department, yet, when taxpayers request the information that the IRS considered in their own audits, the IRS may argue that the statute prohibits disclosure. Understanding the mechanics of the statute is crucial to successfully managing the flow of information in modern tax controversies.
In this new Bloomberg BNA webinar, Mayer Brown lawyers, John T. Hildy and Anthony D. Pastore provide in-house and outside practitioners with a primer on section 6103, an update on recent developments in the case law and advice on how to address common issues in section 6103 disputes.
Topics to be covered:
- The basic mechanics of section 6103
- The most important exceptions, including the transactional relationship exception and the item exception
- Recent case law in the Tax Court
- Strategies for obtaining information that the IRS used in audit
- How the statute impacts your ability to obtain a protective order in tax litigation
CLE will be provided by Bloomberg BNA.
Instructions for accessing the program will be sent prior to the event.
If you have any questions regarding receiving continuing education credit, please contact the accreditations team at email@example.com.
For additional information, please contact Shilpa Patel at firstname.lastname@example.org or +1 312 701 8487.
Please visit bna.com.
11:30 a.m. – 12:30 p.m. EDT
10:30 a.m. – 11:30 a.m. CDT
9:30 a.m. – 10:30 a.m. MDT
8:30 a.m. – 9:30 a.m. PDT
5:30 p.m. – 6:30 p.m. CEST
4:30 p.m. – 5:30 p.m. BST