Tax practitioners provide tax advice to clients on a continuing basis and should be familiar with the applicable standards for providing such advice, including Circular 230, the AICPA’s Code of Professional Conduct, and the AICPA’s Statements on Standards for Tax Services (SSTSs). CPAs need to keep excellent documentation of all tax research in accordance with these standards.
CPAs should also maintain an appropriate research library. Maintaining a tax research library is different for each CPA firm and will depend on the practice areas, size of the client base, and budget. With any tax research library, the relative authority must be kept in mind. Some sources are not authoritative and provide only guidance; these sources should not be cited as legal authority. It's also important to distinguish between primary and secondary sources. Primary sources are documents issued by the government. Secondary sources are prepared by vendors who provide tax research services, legal analysts, scholars, and tax professionals.
This resource page serves to help members understand the hierarchy of taxing authorities, effectively perform and document client research, and communicate findings to clients and other stakeholders.
- New! Tax Research and Advice Memo : Template for practitioners to use to document oral and written tax advice.
- New! U.S. Federal Tax Law Hierarchy Quick Reference Chart: Summarizes the weight of authority from highest to lowest for use in determining whether a source can be relied upon for a tax position.
- Tax Research Techniques presentation : Archived webcast that discusses how to effectively research, resolve, and document tax issues.
- Tax Research Techniques, 10th Edition: Authors reveal how to ask the right questions, organize the facts, locate and assess pertinent authority, and clearly communicate research findings (available to purchase in the AICPA Store).
- Tax Research 1, May 18 (1pm ET): This webcast provides a working knowledge of the methodology of implementation-based tax research. Drawing on the latest developments in online research, this webcast describes how to ask the right questions, organize the facts, locate and assess pertinent authority, and clearly communicate research findings.
- Tax Research 2, May 19 (1pm ET): This webcast focuses on learning to identify and phrase tax questions. It will also cover assessing and applying authority and external communications. Take a deeper dive into the elusive nature of tax questions.
- Legal Bitstream: Provides a database offering of advanced searches for tax cases (1990 to present), regulations, and many other administrative documents.
- IRS Guidance for Tax Professionals: Contains primary federal sources, forms, publications, and other items from the IRS.
- Legal Information Institute at Cornell Law School: Contains primary U.S. federal and state sources and a secondary source legal dictionary and encyclopedia (Wex) built by the law school.
- Harvard Law School: Contains primary U.S. federal and state sources, U.S. treaties, foreign and international law, and a number of secondary sources (journals, legal dictionary, encyclopedia, etc.).
- NYU Law School - GlobaLex Hauser Global: Contains guides dedicated to international and foreign law research. Guides provide overviews and references to primary and secondary sources.
- Internal Revenue Manual (IRM): Discusses the procedures that IRS employees must follow to administer fair tax administration (this is essentially the IRS's employee handbook). It is helpful to research the IRM when preparing for an audit, responding to a notice, or helping a client with various IRS issues (penalties, collection, innocent spouse relief, identity theft, etc.).
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