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IRS Fishing Expedition Is Successful and Raises Important Attorney-Client Privilege Concerns

The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more

The Reasonable-Basis Defense: Waiver of Attorney-Client Privilege?

This Holland & Knight alert is not focused on the structured trust advantaged repackaged securities (STARS) transaction or the economic substance doctrine, which were the primary issues before the U.S. Court of Appeals for...more

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