July 30, 2020 from 12-1 pm EST.
Attorney-Client Privilege/ Legal Professional Privilege in Tax Planning – UK Perspective presented by
Patrick Harney, Mishcon de Reya LLP
Robert Hartley, Mishcon de Reya LLP
Christiana Lazo, Kirkland & Ellis
Day one bear traps: is it privileged and whose privilege is it?
Sharing privileged documents with advisers and other principals
Loss of privilege, including collateral waiver
Practical points to consider, especially post-execution
Disclosure exercises and privilege
Attorney-Client Privilege in Tax Planning – US Perspective
Basics – What is Privileged, Whose Privilege is It and How is it Waived?
Tax Return Reporting
Kovel Letters – When They Work (and When They Don’t)
Comparison of Additional Protections – IRC § 7525, State-Created Accountant-Client Privileges and Work Product Doctrine
UK Proceeds of Crime Act 2002 – International Trend?
Exceptions to solicitor-client privilege
Requirement to report suspicious transactions
Offence of “tipping off”
Illegal Activities, Legal in Other Jurisdictions
Impact of DAC6 on US inbound planning
Comparison to US Reportable Transactions