The Supreme Court Punts in In re Grand Jury. Where Does That Leave Attorney-Client Privilege and Tax Advice?
Holland & Knight CPA Webinar Series
In the case of In re Grand Jury, in January 2023, the Supreme Court of the United States dismissed the writ of certiorari as improvidently granted. This leaves the issue of the attorney-client privilege in the context of tax return advice and the applicable standard to apply — the primary purpose or the significant purpose test — in limbo.
Please join Holland & Knight tax attorneys Denise Mudigere and James Dawson, along with Caplin & Drysdale member Christopher Rizek, as they explore the standards under consideration, the potential impacts under each of the standards as it applies to tax communications and whether the courts are missing a central issue as to tax advice.