On June 1, 2022, WLF urged the Supreme Court to hear an important case about the attorney-client privilege.  The Ninth Circuit held that a document containing legal advice is not privileged if the primary purpose of the document is to provide tax advice. WLF’s amicus brief explains how this rule will cause companies to curtail internal investigations. Next, the brief argues that even if the holding is limited to tax advice, it exemplifies tax exceptionalism. Finally, the brief explains that review is necessary to ensure uniform application of Rules 26 and 501.

Documents

WLF amicus brief