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.

Learning Objectives
  • Explore the scope and limitations associated with the principal types of protection that apply with respect to confidential communications and documents, including the attorney-client privilege, the Section 7525 tax advice privilege and the work product doctrine.
  • Discover how Kovel arrangements can be used to protect against disclosure in situations where advice is required from both attorneys and non-attorney practitioners, and how those arrangements should be documented and implemented.
  • Recognize how confidentiality protection can be destroyed through waivers (which can be inadvertent) and by other disclosures.
  • Identify best practices that can be implemented to obtain and preserve confidentiality protection, including steps that can be taken to avoid such waivers.
Last updated/reviewed: March 18, 2024
1 Review (2 ratings)

Reviews

4
Anonymous Author
Excellent course with practical insights. Very well prepared and presented.

Prerequisites
Course Complexity: Foundational
Fundamental knowledge of common tax, business and legal terms. (Finance, accounting and legal professionals, and business owners and managers with some tax background would generally have this knowledge.)
Education Provider Information
Company: Illumeo, Inc., 75 East Santa Clara St., Suite 1215, San Jose, CA 95113
Contact: For more information regarding this course, including complaint and cancellation policies, please contact our offices at (408) 400- 3993 or send an e-mail to .
Instructor for this course
Course Syllabus
INTRODUCTION AND OVERVIEW
  Course Scope3:10
  Overview - Principal Types of Protection7:10
  Attorney Client Privilege11:20
  Section 7525 Tax Advice Privilege6:36
  KOVEL Arrangements5:06
  Work Product Doctrine4:32
  Confidentiality Practices5:50
  Confidentiality Practices Cont'd15:20
CONTINUOUS PLAY
  Privileges and Protection: Preserving Confidentiality of Communications and Documents59:04
SUPPORTING MATERIAL
  Slides: Privileges and Protection: Preserving Confidentiality of Communications and DocumentsPDF
  Privileges and Protection: Preserving Confidentiality of Communications and Documents Glossary/ IndexPDF
REVIEW AND TEST
  REVIEW QUESTIONSquiz
 FINAL EXAMexam