International Tax Disputes Insights Newsletter (Spring 2021)

06 May 2021

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 times generates important discussions and developments such as in the cases we discuss herein. In the United States, two decisions, Microsoft and Sanmina, offer especially dynamic opportunities to consider the contours of the privilege and other American protections. In the United Kingdom, Sports Direct Group considers the application of a specific type of protection, the litigation protection, similar to the work product protection in the United States. The rules of privilege and work product are essential features of legal systems that utilize adversarial efforts to produce just resolutions. Without such protections, persons subject to the law would be reluctant to obtain advice from counsel and hesitant to carry on a robust discussion of competing legal positions leading up to a dispute. Such protections are all the more important the more complex and onerous a legal system is.

As with this issue, our future issues will focus on important tax controversy developments around the world to assist taxpayers on a global scale.

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