Kovel Arrangements to Preserve/Create Attorney Client Privilege

Jul 09, 2023 0 Replies

Hi everyone hope all is well. This is a very esoteric question. I'm lead Defense Counsel on an IRS Joint Criminal and Civil investigation. I want to bring in a new CPA to do some forensic work in the hope it benefits the client but I want to set this up using a Kovel Letter arrangement among Attorney/Accountant/Client.



Have any of you participated in such Legal Defense structuring? Have Kovel arrangements, which have been "around" since I was an Attorney at IRS, been challenged at any level of an investigation up to and including issuing a Subpoena for the testimony etc. of a "Kovel-ized" Accountant?



I of course will intensify my Research if I decide to go that route, but for now any informed experiential feedback would be helpful. thanks in Advance.


Join the Discussion

Have something to add? Share your thoughts — no account required.

Didn't find your answer?

Ask the community — no account required