Tag Archives: tax practitioner

IRS Circular 230 – Requirements for Covered Opinions

June 27, 2013  |   Posted by :   |   Circular 230   |   0 Comments

Sec. 10.35: Requirements for Covered Opinions Sec. 10.35(a): A tax practitioner who provides a “covered opinion” shall comply with the standards of practice under Sec. 10.35. Sec. 10.35(b)(2)(i): A “Covered Opinion” is written advice on one or more federal tax issues, arising from: (A) A transaction, that at the time the advice is rendered, the […]

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IRS Circular 230 – Return of Client’s Records

June 26, 2013  |   Posted by :   |   Circular 230   |   0 Comments

Sec. 10.28 Return of Client’s Records (a) A practitioner must, at the request of a client, promptly return all records of the client, that are necessary for the client to comply with their federal tax obligations. The practitioner may retain copies of the records returned to a client. The existence of a dispute over fees […]

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IRS Circular 230 – Required Disclosures – Covered Opinion

June 23, 2013  |   Posted by :   |   Circular 230   |   0 Comments

Sec. 10.35: Required Disclosures: Covered Opinion Under Sec. 10.35(e), a covered opinion must contain all of the following disclosures that apply: 1. Relationship between promoter and practitioner: (i) Any compensation arrangement such as a referral fee, or a fee-sharing arrangement between the practitioner and any person (other than the client for whom the opinion is […]

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IRS Circular 230 – Requirements for Other Written Advice

June 20, 2013  |   Posted by :   |   Circular 230   |   0 Comments

Sec. 10.37: Requirements for Other Written Advice Sec. 10.37(a): Requirements. A tax practitioner must not give written advice concerning one or more federal tax issues if the practitioner bases the written advice on unreasonable facts or legal assumptions (including assumptions as to future events), unreasonably relies upon representations, statements, findings or agreements of the taxpayer […]

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IRS Circular 230 – Limited Scope Opinions

June 18, 2013  |   Posted by :   |   Circular 230   |   0 Comments

Sec. 10.35 Covered Opinions – “Limited Scope Opinions” Sec. 10.35(c)(3)(v). The practitioner may provide an opinion that considers less than all of the significant federal tax issues if: 1. The tax practitioner and the taxpayer agree that the scope of the opinion and the taxpayer’s potential reliance on the opinion for purposes of avoiding penalties that […]

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IRS Circular 230 – Tax Practitioner Fees

May 09, 2013  |   Posted by :   |   IRS Tax Audits   |   0 Comments

10.27 Fees (a) A tax practitioner may not charge an unconscionable fee in connection with any matter before the IRS. (b)(2) A tax practitioner may charge a contingent fee for services regarding IRS examination or challenge to: 1. Original Tax Return; 2. Amended Tax Return, or Claim for Refund (where the amended return or claim […]

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IRS Treasury Department Circular 230 – Tax Advisors

May 03, 2013  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

Effective August 2011, the Treasury Department issued Circular No. 230 (Title 31 Code of Federal Regulations, Subtitle A, Part 10): Regulations Governing Practice before the IRS. Tax advisors must comply with the requirements (of Circular 230) or face IRS disbarment, censure or sanctions. Under Circular 230 the following rules apply: 1. Sec. 1021: A practitioner […]

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FBAR – Tax Practitioners and Professional Responsibility

January 10, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

U.S. Taxpayers, who fail to file FBAR’s to disclose foreign bank accounts, may seek a reasonable cause exception based on their “tax preparer’s” failure to file the FBAR. Tax Practitioners (Attorneys, CPA’s) must comply with the FBAR rules as part of their due diligence (as to accuracy) obligation under IRS Circular 230 (Section 10.22). The […]

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