In brief After initially granting certiorari and hearing oral arguments in In re Grand Jury ─ a matter concerning the application of the attorney-client privilege to dual-purpose communications ─ the United States Supreme Court “dismissed as improvidently granted” the case. Tax practitioners had hoped that a ruling by the Supreme Court would resolve a circuit split regarding the extent to which such communications fall within the ambit of the privilege. Background As a general rule, a lawyer’s…
Robert Hammill is a partner in Baker McKenzie's Palo Alto office, where he advises on tax controversy, tax planning, and transfer pricing matters. Robert's practice focuses on federal tax controversies, primarily in transfer pricing and other international tax issues. He represents clients at all stages of federal income tax controversies, including audit preparation and management, during administrative appeals, and before the US Tax Court. He works with companies in the pharmaceutical, biotechnology, software, semiconductor, and e-commerce industries.