IRS Circular 230

CD of Live 90-Minute Telephone Conference with an Interactive Q&A Session Conducted on December 7, 2005 Now available on CD

The recent IRS regs amending Circular 230 practice standards for tax advisors, such as attorneys and CPAs, have a greater impact on corporate tax executives and in-house tax counsel than you may have thought.

Although tax practitioners on the corporate payroll are free from some of the Circular 230 requirements for covered opinions, this exception is limited to advice provided solely for purposes of determining the employers' tax liability.

In addition, it’s vital for corporate tax personnel to clearly understand both the risks and protections offered by various forms of tax advice that they receive from outside tax counsel -- and properly interpret the presence or absence of a Circular 230 disclaimer.

Listen without leaving your office as our panel of veteran tax advisors walks you through every key section of the new Circular 230 regs - and gets to the bottom line for the corporate client.

They’ll offer guidance on these and other key issues:

• What accountability and potential liability the Circular 230 rules create for corporate tax executives and in-house tax counsel.
• What a tax attorney or CPA now means when he or she asserts reliance on facts, assumptions, and representations provided your company.
• How to determine the scope of opinion coverage at the outset of an engagement with Circular 230 in mind.
• How to treat written tax advice from outside advisors prudently, while ensuring that you are getting the full value of the guidance you're paying for.
• How to filter what you hear as tax advisors try to stay within the new minimum standards for non-written advice.

Our panelists -- all authorities on Circular 230 and federal tax issues-- include:

Susan Glenn, Coordination and Review Counsel, Morrison & Foerster, New York, is a member of the firm's Tax Department and focuses her practice on federal tax matters.

Alice A. Joseffer, Partner, Hodgson Russ, Buffalo/New York City/Toronto/Boca Raton, Florida, is a member of the firm's General International Tax Practice Group and Tax Dispute Resolution Practice Group. Her federal and international tax practice includes representing clients with tax controversies.

Mark Stone, Federal Tax Partner, Holland & Knight, New York, practices in the area of corporate, international, and real estate taxation and has considerable experience in the representation of non-U.S. companies.

Robert Walton, Partner, Baker & McKenzie, Chicago, is a member of the firm's Tax Controversy & Litigation Practice. He works with clients at all stages of tax controversies from the audit level to IRS Appeals to litigation in the Tax Court.

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