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Internal Revenue Code (IRC) Attorney-Client Privilege Internal Revenue Service

McDermott Will & Emery

Key Takeaways | Don’t Be Privileged When Asserting Privilege

McDermott Will & Emery on

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

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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