International tax enforcement is a top priority of the IRS and the Department of Justice. Audits and investigations routinely involve the collection of information, documents, and testimony outside the United States, leaving tax practitioners to determine what, if any, privilege applies and how those privileges can be preserved in various jurisdictions. This panel of experienced tax controversy attorneys addressed common privileges that arise in tax matters, the holder and scope of those privileges, the extent to which such privileges can be waived or set aside, and how to navigate these waters in foreign and cross-border audits and investigations.
Moderator: Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
Mark D. Allison, Esq., Member, Caplin & Drysdale, Chartered, New York, NY
Mark F. Daly, Esq., Litigation Counsel, Tax Division, US Department of Justice, Washington, DC
Sarah E. Paul, Esq., Partner, Eversheds Sutherland (US), New York, NY
Carolyn A. Schenck, Esq., Senior Counsel, Office of Chief Counsel, Internal Revenue Service, St. Paul, MN
Click here for more information