שטוטאקוי, אתר מאמרים אישי

The Schaeffler Group engaged legal counsel and an accounting firm to advise them on the assessment and minimization of the tax consequences of the restructuring and refinancing, knowing that the transactions would likely be subject to irs review.17 As part of the refinancing and analysis of their tax implications, the Schaeffler Group shared documents containing privileged tax advice. under a joint interest agreement with the consortium.18 The IRS subsequently subpoenaed the documents with the legal tax advantage. Ice. The Schaeffler Group revoked the subpoena and withheld the documents on the basis of the common interest privilege and the lawyers` work product doctrine.19 Schaeffler v. United States15 shows how courts analyze common interest privilege and the importance of a common interest agreement in the tax context. Schaeffler participated in the restructuring of the Schaeffler Group – a German company that holds 80% of its shares in an American company. .