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IRS Proposes New Obligations for Tax Advisers

By Mark L. Silow, Esq.
February 01, 2004

With the stated purpose of restoring, promoting and maintaining the public's confidence in professionals providing tax advice, the Internal Revenue Service has issued proposed regulations that set forth “best practices” applicable to all tax advisers and mandatory requirements for advisers who provide certain tax shelter opinions.

These proposed regulations, issued on Dec. 29, 2003, apply to all tax advisers who practice before the IRS (eg, lawyers and accountants) but are not intended to alter or supplement other ethical standards applicable to practitioners (such as the Rules of Professional Conduct). The proposed regulations are to become effective on the date of publication of final regulations.

The proposed regulations would amend Circular 230, which was originally issued by the IRS to provide standards for tax opinions rendered in connection with tax shelter transactions. The proposed regulations would expand the scope of Circular 230 by imposing the following new requirements:

  • A set of “best practices” applicable to all tax advisers.
  • Specific standards for tax advisers who provide tax shelter opinions that constitute either “marketed tax shelter opinions” or “more likely than not tax shelter opinions.”
  • Compliance procedures for tax advisers and firms that employ tax advisers.

Best Practices Defined

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