This article discusses the technical provisions of Circular 230, Regulations Governing Practice Before the Internal Revenue Service, and how recent revisions could affect existing tax practice procedures and the management of tax practices.
Circular 230 Guidance
Practitioners’ Responsibilities in Complying With Records Requests
When responding to records requests, the tax practitioner must be cognizant of, and adhere to, the collective body of applicable professional standards and law.
New Rules for Providing Written Tax Advice Are Finalized
The IRS issued final regulations under Circular 230 on the rules for practitioners to provide written tax advice and certain other related provisions.
Circular 230 Case Processing and the Application of Monetary Penalties
One of the biggest issues practitioners have with the IRS Office of Professional Responsibility is a lack of information on what constitutes a violation of Treasury Circular 230 and how OPR applies sanctions for such violations.
Practical Approaches to Common Conflicts of Interest
This column highlights some common conflicts of interest encountered by CPA tax practitioners and offers some practical means of properly addressing the consequential ethical issues.
An Overview of AICPA and IRS Rules of Practice
This column refreshes practitioners on the AICPA and IRS rules of practice, provides a list of resources for questions and answers, and details the relationship and similarities between the AICPA and IRS ethics standards related to tax practice.
Taxpayer Representation in the Shadow of Preparer Discipline
Tax practitioners at times must balance client interests and their own professional interests. This issue takes on even greater import when the CPA is representing a client before the IRS.
Advising Clients Regarding Erroneous Tax Return Positions: Part II
This article discusses what tax practitioners must do if their client fails to heed their advice whan an error is found on a tax return and what to do when the error is attributable to the tax practitioner’s own advice.
Advising Clients Regarding Erroneous Tax Return Positions: Part I
This article examines the two somewhat different versions of the rule on advising clients regarding erroneous tax return positions—one applied by the AICPA and the other by the IRS.
Amendments to Circular 230 to Remove “Covered Opinion” Rules
When issued in final form in 2013, Circular 230 amendments are likely to have an important impact on CPAs and other tax representatives.
IRS Proposes Changes to Circular 230 Rules Governing Written Tax Advice
The IRS released proposed regulations that would eliminate the complex rules in Circular 230 governing covered opinions.
Circular 230, Section 10.21, and SSTS No. 6: Standards Relating to Taxpayer Errors and Omissions
Circular 230 SSTS No. 6 impose standards of conduct on CPAs who discover an error or omission in a prior-year tax return.
Interpretations of SSTS No.1, Tax Return Positions
Recently issued revised and updated interpretations of the AICPA’s SSTS No.1, Tax Return Positions, provide guidance to practitioners on tax reporting standards when recommending return positions or preparing or signing returns.
Due Diligence Update
This column discusses the tax professional’s due-diligence obligations under SSTS No. 3 and Circular 230.
The RPO, OPR, and Circular 230
A discussion of developments in two critical IRS offices, the Return Preparer Office and the Office of Professional Responsibility.
Integrating Circular 230 into the Tax Curriculum
Circular 230 is crucial to tax education because it forms the ethical standards of tax practice. Students who plan to become tax practitioners must become well acquainted with Circular 230 along with the underlying laws and regulations governing tax practice.
Integrating Circular 230 into the Tax Curriculum: Appendix
This appendix provides a more detailed suggested solution to the five questions presented in the Feb. 2012 Campus to Clients column.
Circular 230: Its Day-to-Day Impact on Tax Practices
While discussions about Circular 230 usually focus on the standards it imposes relating to tax returns and opinions, the breadth and scope of Circular 230 also regulates the day-to-day business operations of tax practitioners relating to fees, client solicitations, marketing and advertising, and the management of client files and records.
2010–2011 Revisions to Circular 230
This article focuses primarily on the Circular 230 tax preparer penalties and other sanctions as well as the regulations governing practice before the IRS that were revised by T.D. 9527.
Conflicts of Interest: IRS Rules Differ from AICPA Professional Standards
Circular 230 forbids federal tax practitioners from having conflicts of interest, defined as representation of one client that is directly adverse to that of another client, or representing a client in circumstances creating a significant risk that the representation of one or more clients will be materially limited by the practitioner’s responsibilities to another client, a former client, or a third person or by a personal interest of the practitioner.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.