...A communication must be made for the purpose of legal advice to be protected from disclosure by the attorney-client privilege. If legal advice is not the purpose of the communication, the attorney-client privilege does not...more
The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more
In Taylor Lohmeyer Law Firm P.L.L.C. v. United States, No. 19-50506, the United States Court of Appeals for the Fifth Circuit held that a Texas-based estate and tax-planning law firm (Firm) could not invoke 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
It's Monday morning and your client, who recently retained you for estate tax planning advice, informs you that the IRS is auditing her income tax returns from the past three years. In reviewing her tax returns and financial...more