REGULATION Flashcards
WHEN IS THE TAX REPRESENTATIVE MADE TO HAND OVER TAX INFORMATION?
IN every situation UNLESS, it is a situation of PRIVILEGE. OTHERWISE, it must be handed over PROMPTLY
A practitioner may not charge a contingent fee for providing services before the IRS, with 3 EXCEPTIONS
For services rendered in connection with an IRS examination or challenge to either
A(i) an original tax return or
(ii) an amended return or claim for refund when they were filed within 120 days of receiving a written notice of examination or written challenge to the original exam
B) Where a claim for refund is filed solely in connection with determination of statutory interest or penalties
C) When the accountant is representing the client in judicial proceedings
In these three situations, the threat that the tax practitioner and client will play the “audit lottery” (taking an aggressive position because it is unlikely that the Service will substantively examine it) is small.
PCAOB meaning
PUBLIC COMPANY ACCOUNTING OVERSIGHT BOARD
PCAOB
believes that a public company auditor is not independent from an audit client if it offers that client any services on a contingent fee basis
CONFLICT OF INTEREST
Section 10.29 provides that practitioners should NOT REPRESENT a client before the IRS if to do so would create a CONFLICT OF INTEREST
When can a CPA LICENSE BE REVOKED
FAILURE TO FILE TAXES, FELONY, FILING FRAUDULENT TAX RETURN, AIDING IN FILING FRAUDULENT TAX RETURN,