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What is a Kovel accountant? An accountant who is brought under the cloak of the attorney-client privilege, which is considered stronger than the tax practitioner-client privilege.

In this course, tax attorney Mike DeBlis explains Kovel agreements and discusses the case that gave rise to them.

This course delves into the complex interplay of legal privileges, including the attorney-client privilege, work product doctrine, and the federally authorized tax practitioner privilege (IRC 7525).

Learn why the standard tax practitioner privilege often falls short, especially when facing IRS scrutiny or potential criminal investigation. Discover how the landmark Covell case and subsequent strategies allow attorneys to bring the crucial work of forensic accountants under the stronger protection of the attorney-client privilege, safeguarding sensitive client financial information.

Key topics covered include:

• Understanding the scope and limitations of various legal privileges in tax matters.
• Distinguishing between legal advice and tax preparation work for privilege purposes.
• Structuring a proper "Covell agreement" to protect accountant-client communications.
• Strategic considerations for engaging accountants in tax defense, particularly during "eggshell audits."
• The risks and pitfalls of using a client's existing accountant vs. hiring a new one.
• Practical steps to create an airtight Covell arrangement and navigate client concerns.

Gain essential knowledge to effectively utilize accounting expertise while maximizing privilege protection for clients navigating high-stakes tax situations.