To help ensure professionals understand their ethical responsibilities in representing their clients before the Internal Revenue Service (IRS) and in preparing client tax returns, the IRS has published Treasury Department Circular 230, which offers substantial guidance. Expert tax practitioners use realistic scenarios to show how tax lawyers and CPAs can identify and defuse potential ethical bombshells when the IRS comes calling. Attorney-client, tax practitioner privilege, and conflicts of interest are evaluated and explored. Special ethical issues in representations with international tax implications are identified. The impact of the latest revisions to the Circular 230 regulations and the IRS loss in the Loving case are also uncovered.
Summary of Contents
Attorney Client and Tax Practitioner Privelege, including Kovel Letters and Confidentiality
Amendments to Circular 230, June 12, 2014, including “Written Advice” and “Competence”
Conflicts of Interest Issues in Tax Practice
Circular 230 Under Attack: The Effects & Implications of the Loving and Ridgely Cases