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Supreme Court to Hear Case on Client-Attorney Privilege in the Context of Dual-Purpose Legal Advice

04 October 2022

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Proposed Changes

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United States

The United States Supreme Court on 3 October 2022 accepted to review a case dealing with the legal protection of client-attorney communications in situations where the communication deals with both legal and non-legal matters (so-called dual-purpose communications). The petitioner in the case is an international tax law firm seeking to shield client communications from grand jury subpoenas seeking documents on its tax advice to the client. The petitioner assisted one of its clients on matters regarding the tax consequences of their anticipated expatriation and prepared for the client several individual income tax return and their Form 8854. In connection with...