New penalty rules for tax return preparers pose significant challenges for tax practitioners and their clients. There often is a great amount of uncertainty about what a “tax shelter” is and when and how to disclose return positions. Practitioners must also wrestle with regard to conducting proper due diligence, understanding the standards of conduct necessary to avoid 6694 penalties and determining when to rely on information provided by clients or third parties. If these weren’t enough, what else may lie ahead?
The Knowledge Group has assembled a panel of experts to help tax practitioners understand these concerns. In addition, this Live webcast will feature a bonus segment on estate and gift tax issues. Join this webcast by clicking on the “Register” button below. Advanced registration is recommended as space is limited. Register today to guarantee yourself a space in this must attend webcast.
Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Conference
Recommended CLE/CPE Hours: 2.0
(Please note, your State Bar or Accounting Board will make the final determination with respect
to continuing education credit.)
Advance Preparation: Print and review course materials
Course Code: 093855
Evelyn Elgin
Principal, National Tax Office
Alvin S. Brown. Esq.
Tax Attorney
Michael J. Desmond
Partner
Arthur J. (Kip) Dellinger, Jr., CPA
Chair, Tax Practice Responsibilities Committee, AICPA Tax Division, Partner
Evelyn Elgin, Principal, National Tax Office, KPMG LLP
- A preparer’s responsibilities regarding disclosure of return positions
- Problems associated with “tax shelters”
- Mechanics of disclosure
- Special considerations in the case of the penalty for disregarding rules or regulations
- Impact of potential changes to the taxpayer accuracy-related penalty regulations on preparer penalties
Michael J. Desmond, Partner, Bingham McCutchen LLP
- Defining "tax return preparer" -- the scope of the preparer penalty is much broader than you might think.
- What return position standards must be met in order to avoid the penalty?
- Application of the penalty to "significant purpose of tax avoidance" transactions and other open questions.
- Application of the penalty to refund claims.
- What changes to the preparer penalty regime are being considered by Congress and the IRS?
Alvin S. Brown. Esq., Tax Attorney, Alvin Brown & Associates, LLC
- IRS examination of section 6694 issues
- Hidden traps in reliance on client data
- Arcane “substantial authority” standard
- Disclosures with the “reasonable basis” standard are not without serious risk
- Difficult threshold for “reasonable cause”
- The high risk of section 6694(b) penalties
Arthur J. (Kip) Dellinger, Jr., CPA, Kallman & Co. LLP, Chair, Tax Practice Responsibilities Committee, AICPA Tax Division, Partner
- Reliance on client provided and 3rd party information and related due diligence issues
- Application of the penalty to estate and gift tax preparation and advice
- Attorneys
- Accountants
- Corporate Tax Directors and Staff
- Senior Tax Managers
- Tax Partners
This is a must attend event for anyone interested in understanding Section 6694.
- New guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A