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?
Specific Highlights:
Unused Structures
Tax Return Reporting
Crime-Fraud Exception
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

Register Here for the webinar