Representations & Examinations
Tax practitioners can rely on several doctrines
to preserve the confidentiality of client communications, but they must follow appropriate
procedures and provide clear documentation to protect the privilege in IRS exams or legal proceedings.
Proposed regulations provide that the IRS may determine that the centralized partnership audit regime does not apply to adjustments to partnership-related items under certain conditions.
The IRS’s LB&I Division requested comments regarding the potential obsolescence of Rev. Proc. 94-69, under which certain large corporations may
be treated as filing “qualified amended returns” after the commencement of an IRS examination.
The IRS issued rules on two special enforcement matters for purposes of the unified partnership audit rules.
One of the biggest, yet most misunderstood, penalty defenses is that a tax position was based on reasonable cause and the taxpayer acted in good faith.
The IRS said it would once again begin charging fees to issue preparer tax identification numbers to return preparers for 2021.
The IRS has proposed to lower the fee it charges for preparer tax identification numbers (PTINs) when PTIN fees are reinstated.
The IRS launches fresh efforts to promote awareness of data security issues.
The TCJA and the PATH Act expanded the penalties on tax return preparers who fail to follow due-diligence procedures when clients claim certain credits or head-of-household filing status.
The IRS has authority to charge a user fee for preparer tax identification numbers, a federal appeals court held, paving the way for the agency to reinstate the charges for obtaining and renewing a PTIN.
The IRS has authority to charge a fee for obtaining or renewing preparer tax identification numbers.
The IRS has authority to charge a user fee for preparer tax identification numbers (PTINs) a federal appeals court held, paving the way for the agency to reinstate the charges for obtaining and renewing a PTIN.
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
Practitioners should be aware of changes to the due-diligence requirements for returns that claim the earned income tax credit, the American opportunity tax credit, and/or the child tax credit.
Keeping a “scorecard” of the weight of authorities on a particular position can be helpful to determine the objective merits of a tax position.
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
The Court of Appeals for the D.C. Circuit held that the AICPA had standing to challenge the IRS’s Annual Filing Season Program for unenrolled tax preparers but further held that the program did not violate the Administrative Procedure Act.
CPAs can protect tax advice to clients from disclosure by understanding the scope of the Sec.
7525 practitioner-client privilege, when it applies, and what actions can cause a waiver of this
key protection.
Practitioners can protect themselves from significant
penalties by following the IRS’s ‘adequate disclosure’
procedures.
The IRS is now asking taxpayer representatives who call the agency to provide their Social Security number and date of birth to confirm their identity.
