Tax shelter exception to confidentiality privileges relating to taxpayer communications.
Under AJCA Section 813, the corporate tax shelter rule under Sec. 7525 is applicable to all tax shelters. Thus, written communications about tax shelters are not subject to the Code's confidentiality provision. Oral communications are still subject to the privilege.
The provision is effective for communications made on or after Oct. 22, 2004.
FROM PAUL MANNING, WASHINGTON, DC
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|Publication:||The Tax Adviser|
|Date:||Jan 1, 2005|
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