Brazil’s Administrative Council of Tax Appeals (CARF) has reportedly taken a new approach in a recently issued decision concerning the liability of a tax planning advisor for a tax assessment issued to their client. In the past, the CARF typically held that tax advisors, such as accountants, lawyers, etc. had a common interest with their clients when engaged in tax planning, which under Article 124 (I) of the National Tax Code meant the advisor could be held jointly and severally liable for a…