How to Identify a Potential Criminal Tax Matter Requiring an Attorney
This column discusses some of the circumstances where it might be appropriate to refer or involve an experienced criminal tax attorney and the importance of making a timely referral.
Published on May 31, 2013
FIN 48 Compliance Disclosing Tax Positions in an Age of Uncertainty
FIN 48 presents new challenges for taxpayers, auditors, and tax advisers. The disclosures required by the interaction of FAS 109 and FIN 48 will result in greater public disclosure of tax planning techniques, including the strengths and weaknesses of those techniques.
Published on May 10, 2010
Tread Carefully What CPAs Should Know About Tax Fraud
This article examines Sec. 6663 and the civil tax fraud penalty it imposes.
Published on April 19, 2010
State Tax Tribunals Is Taxpayer Representation by CPAs a Potential Independence Problem
This item addresses whether a CPA representing a client in state tax tribunal has impaired his or her independence under the AICPA Code of Professional Conduct.
Published on March 31, 2014
Protecting Communications and Documents From IRS Summons Enforcement
This article examines the rules and definitions that form the basis for the practitioner-client and the work product privileges and identifies certain measures that can increase the protection of sensitive client information.
Published on April 01, 2013
New Tax Preparer Rules for Disclosure and Use of Return Information
The IRS released final regulations under Sec. 7216, providing guidance for tax return preparers about the disclosure or use of tax return information.
Published on January 28, 2011
Tax Practice and the Federal Criminal Code
Tax practitioners and taxpayers can be prosecuted for crimes under the criminal sections of the Internal Revenue Code and under the general criminal provisions in Title 18 of the U.S. Code.
Published on May 11, 2010
Transparency and Compliance in Light of the New Schedule UTP
In April 2010, the IRS issued a draft of Schedule UTP, Uncertain Tax Position Statement, with Announcement 2010-30. This represents an important development in the longstanding and ongoing battle between taxpayers and the federal and state taxing authorities for access to tax accrual workpapers and other tax-related information.
Published on August 01, 2010