Published on 01 Nov 07
by "AUSTRALIAN TAX FORUM" JOURNAL ARTICLE
This presentation covers:
1. Protecting your client's privileged documents:
- What does legal professional privilege mean?
- What is subject to legal professional privilege and what isn't?
- What should you do to protect legal professional privilege?
- Can there be limited waiver of legal professional privilege if you do disclose?
- Dangers of disclosing legal advice so as to run a RAP argument
2. ATO access to accountants workpapers and advice:
- What do the ATO Guidelines say?
- How much protection do they really offer?
- What the courts have said
- What should you do when asked by the ATO to provide your advice and workpapers?
- ALRC recommendation to make accountants tax advice privileged.
Ashley is a Director at PricewaterhouseCoopers. Before joining PricewaterhouseCoopers he was Senior Assistant Commissioner in the Financial Services Industry Group in the ATO. He had 20 years experience in the ATO and was responsible for income tax issues in the financial services industry, including delivery of the compliance program, provision of advice, law reform and managing the ATO’s relationships with the banking industry.
Current at 1 October 2007 Current at 15 October 2007
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