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Kovel Agreement Attorney Client Privilege

In the court`s view, the privilege of applying a solicitor-client relationship had to exist. The main factors of this decision – which is identified by the court – are: The concept of privilege is granted to persons who work in a lawyer/client relationship in many legal matters, including taxation. In addition, tax professionals enjoy a certain degree of privilege under section 7525, privileges of confidentiality with respect to the disclosure of tax payers. However, the privilege generally does not extend to disclosure between a lawyer and a tax attorney in the context of filing a tax return, since tax returns must be forwarded to third parties (i.e., a tax authority such as the IRS). See U.S. vs. Rating, 456 F.2d 142 (8. Cir. 1972) and U.S. vs. Gurtner, 474 F.2d 297 (9 cir.

1973). However, it is not clear where the line between the preparation of the tax return and the tax advice is drawn. It may be clear that certain communications between a subject and a lawyer are not intended to be disclosed to the IRS, for example. B the persuasiveness of the opposing arguments or the evaluation of the IRS`s expected responses to a proposed transaction. Other communications between a subject and a lawyer when making a return is clearly intended to be communicated to the tax authorities when filing the return. There is probably a large category of tax advice where the impact of the tax preparation rule is less clear. A lawyer can advise a client on a transaction that took place in the middle of the fiscal year. The client will consider the Board`s findings when reporting the tax impact of the transaction on its federal tax return. There is no clear rule as to whether a court can view written deliberation as preparation for tax return, and that probably depends in part on other uses for consultation. However, it is clear that when a taxpayer voluntarily passes the advice to the tax administration to assist, for example, in the processing of a position on a tax return, he is no longer protected by privilege.

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