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Deals At Risk: Textron Opens Door to IRS Discovery of 'Tax Accrual Workpapers'
A “silo” might be a farm building, but in the equipment leasing industry it means a “sale-in, lease-out” transaction. While considered fairly routine in most quarters, in recent years the Internal Revenue Service has flagged such deals as potentially abusive tax shelters. SILOs underlie a confrontation between a taxpayer and the IRS in the new First Circuit case of United States v. Textron Inc., __ F.3d __ (1st Cir. Aug. 13, 2009) (available on the First Circuit's Web site). But that decision was not just about the legality or taxing of such leases. Rather, it has grave consequences on a far more sweeping issue: the inability of taxpayers to shield from disclosure so-called “tax accrual workpapers,” documents typically prepared by in-house tax attorneys that set out in detail sensitive areas of tax liability.
The Textron Facts
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Bankruptcy Sales: Finding a Diamond In the Rough
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