Protecting Confidentiality in IRS Summonses,
Tax Accrual Work Papers, FIN 48 Disclosures,
and Litigation
CD of Teleconference with Q&A
Click here for program outline
Conducted on Tuesday, November 11, 2008
Now available on CD
Sponsored by the Legal Publishing Group of Strafford Publications
Many courts rule attorney–client privilege applies when attorneys provide tax advice to clients. Congressional support is demonstrated by Internal Revenue Service Code Section 7525. However, there is considerable confusion regarding when and the extent to which the privilege applies.
Tax counsel face privilege issues in the context of tax accrual work papers, IRS summonings, FIN 48 disclosures, and tax controversies ranging from IRS protests to litigation. Understanding the extent and nuances of the privilege are critical in shielding confidential client information.
Listen as our authoritative panel of tax attorneys examines the attorney–client privilege and its exceptions. The panel will offer their best practices for preserving the privilege and maintaining the confidentiality in providing tax advice.
The panel for this legal event included:
Edward L. Froelich, Of Counsel, Morrison & Foerster, Washington, D.C. He handles controversy matters involving income tax accounting, international tax, listed transactions, stock option tax treatment, and disclosure litigation.
Kenneth B. Clark, Partner, Fenwick & West, Mountain View, Calif. His principal focus is complex federal tax litigation and tax controversy work. He has managed a variety of complex commercial disputes in a number of foreign countries and numerous states.
Norma J. Schrock, Executive Director, Tax Quality and Risk Management Group, Ernst & Young, Washington, D.C. She specializes in federal tax procedure and consults on the application of federal tax procedures to specific factual circumstances. She assists in communicating current developments in tax policy and procedure to tax professionals. Prior to joining E&Y, she was with a major law firm and the Dept. of Justice, Tax Division.
The panel reviewed these and other key questions:
- Under what circumstances does the attorney–client privilege apply in the context of tax advice?
- What privilege issues arise for attorneys in the context of FIN 48-related counsel to clients?
- How have the courts treated privilege in the context of tax accrual work papers?
- What steps can tax counsel take to preserve the privilege and maintain confidentiality?
TELECONFERENCE CD
Purchase a CD-ROM of the full conference proceedings, including Q&A and PDF files of all handouts (available 10 days after the program).
- Regular Price - $297 (plus $9.45 S&H)
- With Teleconference Registration – an additional $75 (plus $9.45 S&H)
CLE credit is available for an additional $65 each for attorneys seeking CLE credits for NY or CT.
Other states may grant CLE credits for listening to this CD - check with your state about applying for self-study credit on CD-listening.
Click here for program outline