When Work Papers are not Subject to the Attorney-Client Privilege

The recent Textron decision is causing quite a kerfuffle. The court permitted Internal Revenue Service to gain access to documents created by the defense-contracting firm to determine whether the company’s calculation of its tax liabilities would pass muster during a possible IRS audit. Textron was trying to shield the documents under the Work-Product Doctrine. Work-Product … Read more »

Waiving the Attorney-Client Privilege By Seeking Tax Advice

The Massachusetts Supreme Judicial Court focused on the issue of whether the attorney-client privilege protected  communications between an in-house corporate counsel and outside tax accountants. Commissioner of Revenue v. Comcast Corporation, et al., SJC-10209 (March 3, 2009). The general rule is that the voluntary disclosure of privileged information to a third party consultant for the … Read more »

Federal Law to Protect Attorney Client Privilege

Senator Arlen Specter of Pennsylvania introduced Senate Bill 445: A bill to provide appropriate protection to attorney-client privileged communications and attorney work product. The bill: “Prohibits federal prosecutors and investigators across the executive branch from requesting or conditioning charging decisions on an organization’s reasonable assertion of attorney-client privilege or decision to pay of attorneys fees … Read more »

Using the Attorney-Client Privilege to Protect Drafts of SEC Filings

Mintz Levin published a client alert about the Roth v. Aon case I mentioned a few days ago: Draft SEC Filings Can Be Protected From Discovery. The lawyers at Mintz have these recommendations: Disclosures that involve legal judgments, discussions of pending litigation, and business matters that the company must disclose for compliance purposes should be … Read more »