The Supreme Court Punts in In re Grand Jury. Where Does That Leave Attorney-Client Privilege and Tax Advice?
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.
Holland & Knight tax attorneys Denise Mudigere and James Dawson, along with Caplin & Drysdale member Christopher Rizek, hosted a webinar to 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.
Other recordings in this series:
- What You Should Know About U.S. Sanctions Imposed on Russian Elites, Proxies and Oligarchs
- IRS Appeals Update
- So, My Client Didn't Report Foreign Assets to the IRS. What Now?
- What You Need to Know About the New IRS Approach for Approving Advance Pricing Agreements and Renewals
- Tax Legislative Update