Communications between a client and attorney may be protected by attorney-client privilege. Communications between a tax practitioner and client are no exception. Attend this newly updated webcast to learn how attorney-client privilege and the work product doctrine apply in federal tax matters so you know which communications, documents, and/or oral testimony must be produced when a subpoena is issued.
Government officials involved in a federal tax controversy often seek to obtain attorney-client communications such as letters, e-mails, and statements. To protect potentially prejudicial, confidential information, you must be extremely knowledgeable on the application of attorney-client privilege and the work product doctrine to federal tax investigations.
Jerald David August will be presenting a two-hour national webcast presentation on "The Attorney-Client Privilege and Work Product Doctrine in Tax Controversies" for the American Law Institute.
Mr. August's presentation will include the following topics:
- Attorney-client privilege and work product doctrine: generally and in federal tax controversies.
- Communications between client and federal tax counsel: privileged or not?
- Application of privilege to business entities.
- Waivers of privilege, including defending the imposition of accuracy-related or other penalties.
- Federal tax practitioner-client privilege under Section 7525.
- Work product doctrine: What is protected from disclosure to the IRS?
- Protection of accountants' and other consultants' communications and work product: applying the "Kovel Rule".
- Application to tax accrual work papers, ASC 740-10 (FIN 48) work papers, and uncertain tax position (UTP) work papers.