A lawyer incorporating international tax structures for clients was demanded by the Israeli tax authorities to disclose documents relating to companies incorporated for clients, specifically corporate documents, bank account opening documents and credit card clearing accounts documents and personal documents of people related thereto and exposing the identity of the beneficial owners of such corporations.
The Court held that attorney-client privilege does not apply to products of the professional services or documents exchanged between the lawyer and third parties on behalf of the client. Specifically, the privilege does not apply to the identity of the client and thus the Court ordered the lawyer to disclose to the tax authorities the names of the clients and the relation of each client to each corporation.