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Internal Revenue Service › Attorney-Client Privilege › Foreign Bank Account Report

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.

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

Holland & Knight LLP

IRS Fishing Expedition Is Successful and Raises Important Attorney-Client Privilege Concerns

Holland & Knight LLP on

The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more

Holland & Knight LLP

The Reasonable-Basis Defense: Waiver of Attorney-Client Privilege?

Holland & Knight LLP on

This Holland & Knight alert is not focused on the structured trust advantaged repackaged securities (STARS) transaction or the economic substance doctrine, which were the primary issues before the U.S. Court of Appeals for...more

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