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Circular 230 Deskbook

by Blattmachr, Gans, Rios
Edition: 2006 w/updates*
13-ISBN: 9781402407543
10-ISBN: 1402407548
Format: Binder/Looseleaf
SKU: ATTY20043

List Price:	$275.00
Our Low Price:	$271.95



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Circular 230 amendments are one of the most significant changes in tax practice in many years. A tax practitioner's failure to comply with these new and extremely broad requirements can lead to censure, fines, suspension, even disbarment.

The Practising Law Institute's The Circular 230 Deskbook makes sure that you satisfy these rigorous new professional standards, which apply to every individual who practices before the IRS and provides written tax advice, including estate planners, divorce lawyers, and elder law attorneys.

To help ensure full compliance with demanding new requirements, The Circular 230 Deskbook offers laminated, quick-reference charts, including a Circular 230 decision tree -- a chart for complying with Circular 230 -- a Covered Opinions checklist -- a tax practitioner conduct chart -- and a reportable transactions decision tree - all of which are also reproduced in the appendix.

The Circular 230 Deskbook examines the new rules for written federal tax discussions (including e-mails and faxes) that are known as Covered Opinions, including how the new rules may inhibit advice and increase costs to clients. You'll get a complete understanding of the six kinds of Covered Opinions that are subject to these new amendments, which are broken down into listed transactions, reliance opinions, marketed opinions, conditions of confidentiality, contractual protection, and arrangements whose principal purpose is the avoidance or evasion of any tax imposed by the IRC. The Circular 230 Deskbook also identifies the five types of written tax advice that are exempt from these new guidelines.

The Circular 230 Deskbook clarifies and analyzes the four principal requirements with which Covered Opinions must comply, and the many secondary rules within each requirement, giving you a full understanding of what you must do to identify and ascertain the facts with reasonable effort, relate the applicable law to the facts, consider all significant federal tax issues, and render compliant conclusions.

Enhanced by sample Covered Opinions and sample disclaimers and warnings, The Circular 230 Deskbook features step-by-step compliance guidance, including detailed drafting instruction for Covered Opinions, and advice on the insertion of e-mail disclaimers -- use of decision-trees to help determine if a writing is a Covered Opinion -- value of an in-house Circular 230 compliance committee -- and the wisdom of contacting clients about the new amendments (including a sample memo to clients).

Table of Contents includes:

Deference: When the Court Must Yield to the Government's Interpretation;

Selected Penalties;

Reporting and List Maintenance Requirements;

Circular 230;

Appendix A Circular No. 230;

Appendix B Circular 230 Addendum (Jult 2002);

Appendix C Circular 230 (1921 Version);

Appendix D Circular 230 Decision Tree;

Appendix E Chart for Compliance with Circular 230 10.35 for "Covered Opinions";

Appendix F Circular 230 Flowchart;

Appendix G Chart: Reportable Transactions;

Appendix H Checklist for Covered Opinions and Other Written Advice About Federal Tax Issues;

Appendix I Analysis of Certain Court-Made or Judicial Tax Doctines;

Appendix J AICPA Bylaws: Section 730;

Appendix K KPMG Indictment;

Appendix L IRS Form 706;

Appendix M IRS Schedule M-3 (Form 1120);

Appendix N IRS Form 2848;

Appendix O IRS Form 8886;

Appendix P Proposed Changes to Circular 230;

Appendix Q General Disclaimer About Circular 230 for Use in General Memorandum About Tax Law Matters;

Appendix R Sample Disclaimers;

Appendix S Sample Framework of a Circular 230 Covered Opinion;

Appendix T Sample Memorandum of Written Advice Not Constituting a Covered Opinion;

Appendix U 18 U.S.C. 207;

Appendix V Proposed Regulations for Practitioners Rendering Municipal Bond Opinions;

Appendix W Summary Order: Long Term Capital Holdings, LP v. United States;

Appendix X Selected Internal Revenue Code Sections and Treasury Regulations Regarding Penalties;

Appendix Y Application for Enrollment to Practice before the Internal Revenue Service.

*Important! Supplement Update Policy: Like most attorney-practitioner titles, this item may be supplemented from time to time with updates by the publisher in order to reflect any changes in the legal topic area covered. These updates are important in ensuring that your item always reflects the most up-to-date legal information. Your purchase price includes the cost of all previous updates and any updates that may be issued within 60 days of your purchase. After that period, subsequent supplements will be sent to you directly from the publisher for your review and purchase.

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