DOJ Tax New Crime-Fraud Strategy (10/3/19)

I recommend to readers this short introduction to DOJ Tax's recent initiatives for the crime-fraud exception to the attorney-client privilege.  Sarah Paul and Daniel Strickland, Tackling the Tax Division’s New Crime-Fraud Strategy (Bloomberg Tax 10/2/19), here.

A good discussion of the attorney-client privilege and the crime-fraud exception in a current context is in Paul Rosenzweig, Michael Cohen, Attorney-Client Privilege and the Crime-Fraud Exception (Lawfare 4/10/18), here.

I have written before on the crime-fraud exception.  Here are some key blog entries (in reverse chronological order):

• Third Circuit Reverses District Court on Application of Work-Product Privilege for Email to Return Preparer (Federal Tax Crimes Blog 1/30/17), here.
• Update on the Zukerman Indictment - Potential Waivable Conflicts of Interest of Advocate as Witness (Federal Tax Crimes Blog 5/28/16; 6/21/16), here.
• Second Circuit Affirms Application of Crime-Fraud Exception to the Attorney-Client Privilege (Federal Tax Crimes Blog 10/10/15; 5/24/16), here.
• Third Circuit on Crime-Fraud Exception to Attorney-Client and Work-Product Privileges (Federal Tax Crimes Blog 12/12/12), here.