Privileges and Protection: Preserving Confidentiality of Communications and Documents

This course explores how to protect confidential communications and materials from inadvertent disclosure to the IRS and other parties. We discuss the principal types of protection available to taxpayers – the attorney-client privilege, the Section 7525 tax advice privilege, and the work product doctrine. We then describe exceptions to such protection, including waivers that can occur unintentionally. Finally, we discuss steps and practices to be implemented to maintain confidentiality and avoid waivers.

This course is designed for accountants, managers, CFOs and other finance professionals, investors, other professionals, business owners and managers, and attorneys that participate in transactions or other arrangements which may be tax sensitive or otherwise come under scrutiny by the IRS or other tax authorities, or which otherwise might become subject to legal controversy.