Webinar(CA): Understanding CPA Communication Privileges in Tax Practice

Description

An overview of confidentiality privileges that shield taxpayer communications with their non-attorney tax professional from discovery by the Federal government in tax controversy matters.
Taxpayers are entitled to assert confidentiality privilege under Internal Revenue Code Section 7525 similar to the common law attorney-client privilege with respect communications with CPAs and Enrolled Agents.
Also, some taxpayer communications with any expert, including CPAs and Enrolled Agents, enjoy privilege protection from discovery by the government under the “work product” doctrine. Additionally, communications between clients, attorneys, CPAs and Enrolled Agents may enjoy privilege protection under the “Kovel” judicial doctrine when the professional is retained to assist an attorney.
Significant limitations attached to non-attorney privileges are critical for tax professionals to understand. Further, to avoid compromising a taxpayer communicating with an expectation of privilege that will not withstand challenge. Presented from the perspective of a non-attorney tax professional with experience in addressing each of the privilege issues in tax practice.

Learning Objectives

Recognize the nature of the common law attorney-client privilege including the various issues surrounding “waiver” of the privilege.
Identify of the nature of protected communications between taxpayer-clients and the non-attorney Federally Authorized Tax Practitioner.
Determine the significant limitations with regard each of the respective privileges.
Obtain an understanding of how to handle privilege communications from a documentation standpoint.

Major Topics

The Federally Authorized Tax Practitioner (FATPs)
Understanding the attorney-client privilege
The Section 7525 Statutory Privilege and Limitations
The Work-Product Doctrine and Privilege and Limitations
Kovel Engagements and Limitations

Provider
California CPA Education Foundation
Course Level
Advanced
CPE Field of Study
Tax
2
Who Should Attend

CPAs, EAs, and other tax return preparers.

Instructor(s)
Arthur Dellinger,CPA
Prerequisites

Tax practitioners with two-years experience and a working knowledge of the AICPA Statements on Standards for Tax Services and IRS Circular 230.

Advanced Preparation

None

Location
Webinar
Register Now
When
Dec 4, 2020
11:30 am - 1:10 pm MDT
Location
Webinar
Total CPE Credits
2
Format
Webinar
Instructor
Arthur Dellinger,CPA

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Webinar(CA): Understanding CPA Communication Privileges in Tax Practice


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