Attorney Client Privledge with tax matters

The confidential privilege created by IRC section 7525 is not universal as it applies to tax professionals. It applies only in non-criminal tax cases. Code section 7525(a)(2). Thus, in any criminal case or investigation, the communications with NON-attorneys are not protected, even if the communications originated in a civil context. See Chief Counsel Advice Memo. 2000-08006. For this reason, if you are not working with an attorney but there may be potential or actual criminal exposure in your case, you need to know about the limitations of code section 7525. You should consider hiring a tax attorney to handle the potential (or actual) criminal aspects of the case. Once an attorney is brought into the case, the attorney/client privilege applies to all communications between the attorney and the client, without regard to the limitations of section 7525.