Published on 01 Nov 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
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.
Carmen leads MinterEllison’s Tax Controversy team. She has over 25 years’ experience managing large and complex tax controversy matters at the risk review and audit stages and in the conduct of tax litigation. Carmen is responsible for the management and conduct of major tax litigation cases on behalf of the ATO and has been on the ATO’s Tax Technical panel of legal service providers since 2007. She also represents large corporates in their disputes against the ATO and applies her insights into ATO processes and decision making to design strategies for the effective management of clients’ tax dispute issues.
- Current at
29 November 2017