The CPA‐Client Privilege under I.R.C. § 7525: The Elusive Definition of “Tax Advice” Available to Purchase

This paper analyzes the privilege extended by I.R.C. § 7525 to protect the confidentiality between federally authorized tax practitioners, such as CPAs, and their clients. Due to the complexity of the elements the article concentrates on the element that triggers the privilege, that is “tax advice.” Congressional intent, I.R.S. interpretations, and all the appellate opinions and the most relevant court opinions in the past 30 years are considered to provide a working definition for “tax advice.”