In-house counsel, tax attorneys and litigators alike were disappointed by the U.S. Supreme Court's recent decision to dismiss the appeal of In re: Grand Jury on grounds that certiorari was improvidently granted.
The...more
Today, the Supreme Court issued a 5-4 decision in Bittner v. United States, ruling that the Bank Secrecy Act’s $10,000 maximum penalty for a nonwillful failure to file a timely and accurate FBAR report accrues on a per-FBAR...more
Today, the United States Supreme Court issued a "non-decision" in In re Grand Jury. The case involved a conflict among federal circuit courts of appeal over which legal test should be applied to evaluate whether so-called...more
...A communication must be made for the purpose of legal advice to be protected from disclosure by the attorney-client privilege. If legal advice is not the purpose of the communication, the attorney-client privilege does not...more