Diane Ring, Showdown or Balancing Act: Reconciling Our Commitments to the Tax System and the Legal System, JOTWELL (Apr. 14, 2026) (reviewing Siddesh Rao (Copenhagen Bus. Sch.), Client-Attorney Privilege: The Last Barrier to Tax Transparency, 18 World Tax J. 1 (2026)):

In a world in which information vital to effective tax enforcement is frequently hidden from view, who should be compelled to provide that information and on what terms? The answers to these questions have large stakes. . . .

[Rao’s recommendation to increase “engagement with the legal profession”] struck me because it engages with a core tension I have been trying to resolve: the tension between the role of tax professionals in tax planning and but also in tax compliance. Long before tax professionals face any requests for information that place privilege in the cross-hairs, those very tax professionals often have been playing an active role in designing their taxpayer clients’ transactions, strategies and reporting positions—conduct that creates its own tensions between taxpayer’s rights to pay as little tax as possible and a tax advisor’s duty to the legal system and society. Clearly engagement with the profession will be important, but what are its limits?