Which of the following communications between an accountant and client are not privileged?
a) An accountant orally communicates to his client that he should set up a foreign subsidiary to shift taxable income to a lower tax jurisdiction.
b) An accountant privately submits to the client a plan for shifting taxable income to a lower tax jurisdiction.
c) During a meeting in which a client is asking for advice relating to criminal fraud, the client tells his accountant that he lied to the IRS.
Communications (b) and (c) are not privileged, the former because it involves a written communication relating to a tax shelter (i.e., any plan or arrangement, a significant purpose of which is tax avoidance), the latter because it is discoverable in a criminal proceeding. Although communication (a) relates to a tax shelter, it was not made in writing.
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A) design control B) randomization C) matching D) statistical control
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