A recent U.S. District Court case, Green v. Beer, et. al., No. 1: 06-cv-4156 (Southern District of New York) addressed attorney-client privilege issues in connection with emails, and ruled legal advice concerning certain aspects of the shelter were protected, while emails shared with the legal clients' financial advisors resulted in waivers of the privilege with respect to those emails. This case should provide helpful guidance to tax counsel providing tax advice in connection with a transaction as to the do's and don'ts of privilege protections.
Our Firm will be glad to furnish a copy of the case upon request.