Federal Tax

Privilege in Tax and Accounting Matters (Portfolio 635)

  • The Portfolio, Privilege in Tax and Accounting Matters, No. 635, examines applicable testimonial and documentary protections in the tax advice and dispute context.

Description

Bloomberg Tax Portfolio, Privilege in Tax and Accounting Matters, No. 635, examines applicable testimonial and documentary protections in the tax advice and dispute context. Like any other regulatory field, common law privileges and protections will apply in the tax context. However, certain considerations are unique to the tax field such as the statutory privilege provided by §7525 and the protection of information contained in tax accrual workpapers. This Portfolio addresses the fundamentals of the attorney-client privilege, the work-product protection and other protections and considers important scenarios for their application.

This Portfolio can be cited as Boylan and Froelich, 635 T.M., Privilege in Tax and Accounting Matters.

Table of Contents

I. Introduction
II. Privileges and Protections
III. Potential Privileges Available in the Life of a Tax Matter
IV. Special Considerations

Boylan_Kim
Kim Marie Boylan
Head of Global Tax
White & Case LLP
Edward Froelich
Edward Froelich
Counsel
McDermott Will & Emery
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