Client-Attorney Privilege in the Context of Trusts Does Not Apply with Respect to the Beneficiaries.
Partners Daniel Paserman (CPA), Head of Tax and Inbar Barak-Bilu (CPA) in a client update regarding a Court decision recently published in a case of a criminal investigation was conducted against two Israeli residents brothers, based on the claim that the assets they owned were presented as the assets of a foreign trust, in which they are the beneficiaries.
The Court ruled that documents that have been exchanged with various representatives of the trust, including consultants, accountants and beneficiaries – are not protected under the protection of attorney-client privilege with respect to tax matters.