Attorney-client privilege does not extend to requirement for cash reporting.
The Tax Adviser › Vol. 25 Nbr. 12, December 1994
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Summary
Courts have extended disclosure of cash transaction requirements to attorneys receiving cash sums in excess of $10,000 despite the fact that disclosure has been asserted to violate the attorney-client privilege. Under IRC section 6050I, disclosure must be made by businesses receiving sums over $10,000 in a single transaction. Disclosure includes identifying the payor. The statute is intended to help the IRS track down unreported income. The federal courts have ruled that such payments are not protected under the Fifth or Sixth Amendments or legal ethics.
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Attorney-client privilege does not extend to requirement for cash reporting.
The IRS and attorneys have had an ongoing disagreement about whether the attorney-client privilege exempts attorneys from being required to report cash payments of more than $10,00...
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