• “Privileged” Information for the World Citizen When Communicating with Tax Attorneys in Multiple Jurisdictions
  • January 30, 2014 | Authors: Eric D. Swenson; Raul Villarreal Garza
  • Law Firm: Procopio, Cory, Hargreaves & Savitch LLP - San Diego Office
  • Globalization has become a constant reality; capital, income, and individuals flow across borders every split second of every day and often require tax advice from attorneys in multiple jurisdictions. This article will: (i) analyze the general rules protecting confidential information provided by clients to their attorneys for the purpose of obtaining tax advice; (ii) discuss the reasons why attorneys are generally precluded from disclosing such information to tax authorities in the course of a tax audit; and (iii) provide a brief comparison of the privileges that may be asserted in the U.S., Mexico, or Brazil (together the “Three Jurisdictions”) when tax authorities request certain confidential information.