On December 18, 2020, Caroline D. Ciraolo participates in a panel entitled “Privileges and Penalties – Maximizing Your Protections and Minimizing Your Regrets” at USA Branch of the International Fiscal Association International Tax Conference.

Description: This panel addresses hot issues and current developments in privileges and penalties. Using the ongoing Sanmina controversy as a springboard the panel illustrates through realistic fact patterns what we know and don’t know about when various privileges attach in the first instance, how taxpayers can share privileged communications with those who need to know (preparers, valuation experts, accountants, counterparties, the IRS), how to avoid having a selective disclosure become a subject matter waiver, and how to avoid other pitfalls and bad consequences.

Chair: Diana Wollman, Cleary, Gottlieb

Panelists:
Caroline Ciraolo, Kostelanetz & Fink
Erin Gladney, Baker McKenzie
Amanda Leon, Caplin & Drysdale

Click here for more information and to register.