Beyond the Alps: Understanding Fishing Expeditions and Attorney-Client Privilege in U.S.-Swiss Tax Administrative Assistance

        On April 3, 2024, the Swiss Federal Administrative Court rendered a judgement on tax administrative assistance, regarding the topics of fishing expeditions and attorney-client privilege between U.S. lawyers and their Swiss clients.  The event that triggered the case was a request for administrative assistance from the U.S. Internal Revenue Service (IRS) to the Swiss Federal Tax Administration (FTA), regarding a U.S. taxpayer (hereafter: the Taxpayer).