FATP Was Promoting a Tax Shelter, Advice Not Subject to §7525 Privilege

Issues related to privilege for documents prepared related to a tax strategy were the issue decided in the case of United States v. Microsoft Corp. et al., US DC WD Washington, Case No. 2:15-cv-00102.[1]  The case involved Microsoft’s tax liabilities for 2004-2006 and a program that was being considered and then implemented to offset an expected increase in taxes.

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