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Internal Revenue Code (IRC) Attorney-Client Privilege

McDermott Will & Emery

Key Takeaways | Don’t Be Privileged When Asserting Privilege

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This session of the Private Client West Coast Forum 2024 identified common types of privilege, highlighting potential pitfalls to avoid and tools to protect a client’s privileged information. Types of privilege include...more

Gray Reed

When is an Accountant Forced to Testify Against Their Client?

Gray Reed on

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

Vinson & Elkins LLP

[Hybrid Event] The New Corporate AMT and Attorney/Client Privilege: Why Your Attorney Should Hire Your Accountant - January 12th,...

Vinson & Elkins LLP on

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

McDermott Will & Emery

Exxon Prevails in $200 Million Tax Penalty Case

McDermott Will & Emery on

On January 13, 2021, the US District Court for the Northern District of Texas ruled in favor of Exxon Mobil Corporation (“Exxon”) in its battle against the government over tax penalties. Exxon filed amended returns for its...more

McDermott Will & Emery

Ninth Circuit Interprets Summons Notice Rules Strictly Against IRS

The Internal Revenue Service (IRS) had broad examination authority to determine the correct amount of tax owed by taxpayers. In addition to seeking information directly from a taxpayer, the IRS is also authorized to seek...more

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