The New Corporate AMT and Attorney/Client Privilege: Why Your Attorney Should Hire Your Accountant
The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP. Anticipating IRS audits, clients may wish to keep confidential various communications created when formulating GAAP positions to minimize their CAMT exposure. The limited privilege tax accountants claim under Internal Revenue Code §7525, however, is not as effective in preserving confidentiality as your tax lawyer’s attorney-client privilege. During this webinar, we’ll explain how engaging accountants through your lawyer can shield the accountants’ work with the more comprehensive attorney-client privilege.
This presentation was recorded and current as of January 12, 2023. Content viewed after this date may no longer be current.
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This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.