Attorney-client privilege and taxes


It's not uncommon for attorneys to push attorney-client privilege as a foolproof system that lets their clients say whatever they want. However, as with so many other things, the attorney-client privilege isn't entirely black and white. Previously, we've written about how Sovereign Management and Legal, Ltd. of Panama markets the use of attorney-client privilege as a shield from the "nosey" eyes of the IRS.


In the latest episode of Parental Advisory, sponsored by IRSMedic, Claudine and I discuss attorney-client privilege, what it protects from, and — just as importantly — what it can't do. Not only that, but we also talk about how Sovereign Management's marketing is completely misleading (or if it's possible that their marketing could be a honey-pot to bait potential tax evaders into divulging incriminating evidence to a bank that may have made a deal with the Department of Justice).

The following is a screenshot (barring our commentary, of course) from Sovereign's "About Us" page.



Do you see how the IRS could use this marketing material as prima facie evidence that you intended to engage in a criminal conspiracy? Do you know that if you engage in a criminal conspiracy, the attorney-client privilege is meaningless? Do you know attorneys tend to think about #1, not their clients, when a criminal investigation is pointed at them?


We don't mean to scare you, but we want you to understand the facts. Attorney-client privilege isn't all-encompassing and anyone telling you otherwise doesn't have your best interests in mind. If you're overwhelmed and need someone to help you determine what's worth pursuing and what should be avoided, don't hesitate to reach out. One call could save you from going down a path that's capable of throwing your entire future into jeopardy. If you have a tax issue you need assistance with, contact us. We can help.