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Every tax practitioner that has clients that could potentially be investigated by the IRS Criminal Investigation Division. You will need to know how to help your client and protect their privilege when this happens.  You will need to work with their attorney to best assist the client.

When high-stakes IRS audits or sensitive financial disputes cross the line from standard tax compliance into potential legal exposure, standard CPA-client confidentiality completely disappears. Under the law, the IRS can subpoena a tax professional’s emails, workpapers, and meeting notes—unless a Kovel Agreement is explicitly in place.

Led by veteran tax authority Charles Montecino, this critical webinar breaks down the legal mechanics of the Kovel doctrine, giving tax practitioners and attorneys the exact blueprint needed to safeguard their clients' sensitive financial data from forced IRS disclosure.

Presented by Charles Montecino, this intermediate-to-advanced session unpacks the strict operational protocols required to successfully deploy and maintain a Kovel arrangement. He will address modern compliance pressures, including landmark federal rulings that show how introducing standard consumer AI tools into legal research can instantly waive your protections. Attendees will learn how to structure engagement letters, manage historical files, and navigate the delicate line between non-privileged tax compliance and highly privileged legal defense.

Learning Objectives:

  • Define the legal origin and strict parameters of the Kovel doctrine and determine when to implement it before an IRS dispute escalates.
  • Contrast the limitations of IRC Section 7525 statutory practitioner privilege against the comprehensive protection of a Kovel-extended attorney-client privilege.
  • Draft and review a standard Kovel retention letter, ensuring critical clauses regarding work-product ownership, billing structures, and attorney direction are flawless.
  • Implement data guardrails that align with current federal case law regarding modern technologies (such as insecure AI platforms) to avoid accidental third-party privilege waivers.
  • Establish strict document management protocols, including specific email banners, segregated physical/digital files, and communication workflows that maintain confidentiality.
  • Identify the "prior knowledge trap" and navigate the high risk of acting as a Kovel accountant for a long-term, existing client where historical records are not protected

Session Highlights:

  • The Anatomy of a Crisis: Recognizing the exact operational red flags—such as multi-year non-filings, hidden foreign assets, or a surprise visit from the IRS Criminal Investigation Division (CI)—that require a Kovel intervention.
  • Substance vs. Form: Why the IRS aggressively targets and challenges superficial Kovel letters, and how to prove the accountant is functioning as an essential legal translator, not just an external auditor.
  • AI and the Destruction of Privilege: A breakdown of the crucial federal ruling (United States v. Heppner), revealing how inputting data into non-enterprise, consumer AI platforms legally acts as a third-party disclosure that obliterates attorney-client privilege.
  • The Compliance Split: How to legally isolate non-privileged tax return preparation from privileged forensic analysis so that filing a Form 1040 doesn't accidentally waive your entire defense strategy.
  • Step-by-Step Engagement Protocol: Who signs the agreement? Who pays the bill? Charles will map out the exact sequence from the initial attorney contact to billing the ultimate client without shattering the legal chain of custody.
Who Should Attend:

  • Certified Public Accountants (CPAs) & Enrolled Agents (EAs) who represent high-net-worth individuals, family offices, or businesses facing aggressive IRS audits.
  • Tax Attorneys and Criminal Defense Counsel seeking to effectively onboard and manage financial experts without compromising their legal case strategies.
  • Forensic Accountants and Litigation Consultants looking to protect their analysis, workpapers, and expert findings from government subpoenas.
  • Tax Managers and Corporate Controllers handling sensitive corporate internal investigations or navigating complex regulatory exposures.

Credits and Other information :

  • IRS CPE Credits: 2.0 TAX
  • Location: Virtual/Online
  • Delivery method: Group Internet Based
  • IRS Course ID: DFFSC
  • Attendance Requirement: Yes
  • Session Duration: 2 Hours
  • Case Studies and Live Q&A session with speaker
  • PowerPoint presentation for reference

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Each webinar wraps up with a Q&A session, giving you the opportunity to interact with industry experts and receive answers to all your queries.

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  • IRS
  • HRCI
  • SHRM

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