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Event 21 Sep. 2022
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Event 06 Jun. 2023
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News 15 May. 2023
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Event 08 May. 2023
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Event 23 May. 2023
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Fernando Tupa Publishes Book on Forum-Specific Consent to International Arbitration in Investment Agreements
Event 03 May. 2023
Dr. Borzu Sabahi to Speak at ICSID-ADGM Joint Conference: Investment Protection and Armed Conflict
Event 19 Mar. 2023
Sebastiano Nessi speaks at Bahrain Business and Legal Landscape Conference
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Curtis Environmental Chair Charles Howland to Moderate Panel Discussion on Latest Developments in Environmental Due Diligence at ABA Masterclass on Environmental Transactions
News 25 May. 2023
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News 06 Mar. 2023
Russia Sanctions at the First Anniversary: An Overview of Current Sanctions in the US, UK, and EU and How Global Companies Can Navigate Evolving and Conflicting Sanctions Regimes
Client Alert 30 Aug. 2022
The EU Adopts the “Maintenance and Alignment” Sanctions Package
Client Alert 24 Jun. 2021
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News 27 Aug. 2015
Curtis senior tax counsel Linda Galler was quoted by Law360 in its August 24th article, “3 Tips for Being Smart about Privilege Waivers in Tax Court.” The article was based on recent rulings by the U.S. Tax Court that attorney-client privilege will not shield private tax opinions when asserting a “reasonable cause good faith” defense to accuracy-related penalties.
Ms. Galler referenced one such case, Eaton Corp. v. Commissioner, in which the Tax Court last April said the IRS was entitled to review six tax opinion letters written by Eaton's lawyers despite the company claiming it relied on self-determination to meet the reasonable basis exception to penalties assessed by the agency.
“Simply by asserting a reasonable cause defense, the taxpayer put at issue all of its experience and knowledge and state of mind,” she said.
She added that the order showed that an attorney representing a client that is under audit or in litigation has to seriously consider privilege issues in deciding whether the client wants to raise a reasonable cause defense.
Ms. Galler told Law360 that attorneys need to think about privilege issues when giving tax advice even before a client is audited or gets caught up in litigation. She noted that the greater the likelihood that the client will ultimately end up asserting a reasonable cause and good-faith defense in court, the more likely it is that that document or that advice will have to be turned over.
“When one gives a tax opinion, and perhaps when one provides any sort of written advice, one can't assume that that document or that advice will be privileged,” Ms. Galler said.