Presentation Title CommPartners演示文稿的标题 commpartners.pptVIP

10C Written Tax Advice Guidelines per Circular 230 Guidelines – Apply to “federal tax matters” (any Code section, tax obligation, or other IRS administered law) Not Written Tax Advice – Tax policy proposals sent to the government or CPE presentations (unless marketing or promoting transactions) Restrictions on Advice – (a) must not be based on unreasonable assumptions, (b) must not rely on unreasonable representations statements of the taxpayer others, (c) must use reasonable efforts to identify and ascertain all relevant facts, (d) must relate applicable law authority to the facts, and (e) must ignore possibility of IRS audit (i.e., playing tax lottery). 10D Reasonable Practitioner Standard Application – In evaluating compliance (considering all facts and client circumstances) Special Scrutiny – Required if practitioner knows or has reason to believe that advised arrangement has a significant purpose of avoidance or evasion of tax “Additional Risk” – Caused by such arrangements requires that the “reasonable practitioner standard” place special emphasis on the practitioner’s lack or knowledge of the taxpayers’ particular circumstances Question 80 Which of the following is subject to the Circular 230 rules on written tax advice on a federal tax matter: submission to the IRS on suggestions for changes to proposed regulations materials used in a CPE course explaining the new tax law c. materials used by a client in promoting a tax planning strategy that was challenged by the IRS in the past d. all of the above Questions? As Time Permits Or contact: NSA EA Review Blog * * Question Answer Explanation 1 b Merely preparing a tax return does not constitute practice before the IRS 2 b A certified financial adviser is not automatically granted representation 3 d Unenrolled preparers may never receive refund checks 4 d All are qualified under the special rules 5 d Neither of these individuals qualify for practice 6 d Individuals under sus