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This series of frequently asked questions (FAQs) explain several privileges and protections that are relevant to a CPA who provides tax services, including the concept of attorney-client privilege, its implication on CPAs and the use of Kovel arrangements in the course of client representation.
May 12, 2011 · As suggested last year, the IRS may become more aggressive about challenging Kovel engagements. Nevertheless, so long as clients and their advisors take steps to protect the substance of the arrangement (including the above considerations), the associated risks can be managed.
What is ‘Kovel Accountant’ Protection. Many years ago, there was an important tax case in the Second Circuit Court of Appeals involving the extent to which the attorney-client privilege applies in conjunction with the advice received from a non-attorney. The name of the case was Kovel. Unfortunately, the holding in Kovel has been ...
Apr 10, 2023 · Apr 10, 2023. --. A Kovel agreement is an arrangement whereby a client engages counsel to provide legal services, and counsel, in turn, engages specialists, such as CPAs, to support its...
A sample Kovel letter agreement that counsel may use to retain an accounting firm to aid counsel in providing legal advice or services while maintaining the attorney-client privilege and attorney work product doctrine protections.
a Kovel agreement should be distinguished from information collected by the accountant as an auditor or in some other capacity. It is appropriate to keep things as separate and well-documented as you can. That may include using a different accounting firm for the audit or other work where possible. Ultimately, though, a Kovel agreement almost ...
Jun 11, 2023 · Summary. The privilege and its cousin, the work-product doctrine, have taken on an almost mythical quality, with many assuming that merely communicating with an attorney protects communications from disclosure in a subsequent litigation or investigation. That assumption is wrong.
