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Internal Revenue Service › Attorney-Client Privilege › Audits

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

When Do You Need a Tax Attorney

Allen Barron, Inc. on

One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more

Allen Barron, Inc.

How to Prepare for an IRS Audit

Allen Barron, Inc. on

We are often asked how to prepare for an IRS audit. The first and most important thing to know is that speaking directly with the IRS is not in your best interest. IRS Revenue Officers (auditors) are skilled interrogators....more

Allen Barron, Inc.

Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?

Allen Barron, Inc. on

Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more

Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

Allen Barron, Inc. on

What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Allen Barron, Inc.

IRS Audit Doesnt Have to Be a Nightmare

Allen Barron, Inc. on

An IRS audit doesn’t have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood...more

Morrison & Foerster LLP

International Tax Disputes Insights Newsletter (Spring 2021)

Morrison & Foerster LLP on

Our inaugural issue focuses on a truly transnational and important rule of law: the attorney-client privilege and related protections against disclosure. While this is a topic common to all areas of law, the tax arena at...more

Proskauer - Corporate Defense and Disputes

Second Circuit Upholds Common-Interest Privilege for Borrower’s Sharing of Legal Advice with Consortium of Lenders

Proskauer - Corporate Defense and Disputes on

The Second Circuit held last week that a borrower did not waive the attorney-client privilege by providing documents to a consortium of lender banks that shared a common legal interest with the borrower in the tax treatment...more

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