Attorney-Client Privilege and Work Product in Tax Controversies: Latest Developments
Protecting Confidentiality in IRS Summonses, Taxpayer Accrual Work Papers, FIN 48 Disclosures, and Litigation
Recording of a 110-minute CLE/CPE webinar with Q&A
This teleconference will provide tax counsel with an analysis of recent developments in the scope of attorney-client privilege and work product for internal corporate tax documents. The panel will outline best practices for protecting the confidentiality of corporate tax documents and shielding from IRS review.
- Case law on work product protection
- Tax court amendments to work product protection
- Application of the “in anticipation of litigation” standard
- Application of the “substantial need and undue hardship exception” standard
- Application to taxpayer accrual workpapers
- Application to IRS summonses
- Application for reporting uncertain tax positions
- Best practices for protecting internal corporate tax documents
The panel will review these and other key questions:
- How have the courts treated privilege and work product with regard to tax accrual work papers and other internal tax documents?
- How does work product protection apply to a corporate taxpayer's obligation to report uncertain tax positions?
- What steps should tax counsel take to maintain confidentiality of client information in tax matters?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Edward L. Froelich
Morrison & Foerster
He has represented corporations, partnerships, and individuals in the administrative and litigation stages of a federal... | Read More
He has represented corporations, partnerships, and individuals in the administrative and litigation stages of a federal tax controversy. He devotes substantial time to following developments in privilege and work product issues as they affect tax controversies, and is a frequent speaker on topics such as privilege, work product, FIN 48, and low-income taxpayer litigation issues.Close
McDermott Will & Emery
She represents clients on major tax controversies with the IRS at audit or appeals, and in tax litigation before the... | Read More
She represents clients on major tax controversies with the IRS at audit or appeals, and in tax litigation before the U.S. Tax Court and other federal courts. She previously worked as a trial lawyer with the U.S. Department of Justice, Tax Division.Close