Bar Exam Toolbox Podcast Episode 204: Listen and Learn -- Scope of Discovery and the Work-Product Privilege
Internal Investigations in the Asia-Pacific Region
Cyberside Chats: Preserving Legal Privilege After a Cybersecurity Incident
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination
Day 15 of One Month to Better Investigations and Reporting-the Parameters of Privileges
Recently, in a criminal case involving a physician who hired an accountant to prepare and submit certain tax forms to the IRS on her behalf, the court denied attorney-client and work-product privilege claims and ordered the...more
A recent decision of the U.S. Court of Appeals for the Fourth Circuit (one among the 13 appeals courts of the U.S. federal court system) underscores the importance of the attorney-client privilege. In a case titled In re:...more
This video is the first in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage one - planning for and handling the IRS examination. He emphasizes the importance of...more
In Schaeffler v. United States, 806 F.3d 34 (2d Cir. 2015), the Second Circuit reversed a district court's holding that (1) a taxpayer waived his privilege protection by disclosing protected legal advice to his lenders, and...more
The Second Circuit held last week that a borrower did not waive the attorney-client privilege by providing documents to a consortium of lender banks that shared a common legal interest with the borrower in the tax treatment...more
The U.S. Court of Appeals for the Second Circuit recently ruled that the “common interest” doctrine protects legal and tax liability analysis prepared for a client and subsequently shared with a consortium of banks providing...more
On May 26, 2015, the Tax Court issued its opinion in Pacific Management Group v. Commissioner, T.C. Memo. 2015-97, holding that a privilege log provided to the Internal Revenue Service (IRS) was inadequate to sustain claims...more
On September 17, the U.S. Tax Court, in Dynamo Holdings LP v. Commissioner, 143 T.C. No. 9 (Sept. 17, 2014), held that a taxpayer could use predictive coding, over the objection of the Internal Revenue Service (IRS), to...more
The U.S. District Court for the District of Delaware recently interpreted the work product privilege in a manner favorable to taxpayers, ruling that documents can be prepared “in anticipation of litigation” even if created...more
On June 4, 2013, the U.S. District Court for the District of Minnesota held that certain information contained in tax accrual workpapers must be disclosed by the taxpayer pursuant to an Internal Revenue Service (IRS) summons,...more
In an important taxpayer victory, a Minnesota District Court ruled in favor of Wells Fargo, holding that the measurement and analysis of its uncertain tax positions was protected from disclosure by the work product privilege....more