The Many Repercussions of Section 6694
IRS issued Revenue Procedure 2008-14 for the purpose determining the sufficiency of tax returns resulting in avoidance of penalties for underpayments of tax, and penalties against tax preparers for irregularities in tax returns. This procedure will cover periods beginning December 31, 2007, including 2008 returns using 2007 forms. Taxpayers, accounting firms, financial advisers, and companies who employ tax preparers should be strongly familiar with this amendment to avoid being sanctioned for possible violation of the restrictions mentioned. The Knowledge Congress is producing a two-hour webinar featuring a panel of distinguished experts who will share their views on the topic.
- Background: Statute history, changes, interim guidance, proposed regs - Returns Subject to Section 6694 - Preparer definition (planning advice, nonsigning preparers, substantial portion) - Accuracy/disclosure standards/rule for signing preparer and for non-signing preparer - Due Diligence – Reliance on Third Party Information - Due Diligence – Industry Practice Rule and Standards of “reasonableness” in different places - Changes to One Preparer Rule - Related issues: multiple penalties per item/return; gross income allocation rule - Related issues (Circular 230, OPR referral, 2007-39 stacking) and Risk management considerations
Who Should Attend:
- Attorneys - Accountants - Corporate Tax Directors and Staff - Senior Tax Managers - Tax Partners
Christopher S. Rizek is a member of the law firm of Caplin & Drysdale, Chartered, in Washington, D.C. He formerly served as Associate Tax Legislative Counsel in the U.S. Treasury Department, Office of Tax Policy, where he helped write tax procedural guidance and legislation, including particularly the Taxpayer Bill of Rights 2 (1996) and the IRS Restructuring and Reform Act of 1998. He has also previously worked in other Washington law firms and as a Trial Attorney in the U.S. Department of Justice, Tax Division.
Mr. Rizek has a bachelor’s degree in philosophy from Dartmouth College and received his J.D. and his LL.M. in Taxation from Georgetown University Law Center. He currently is an Adjunct Professor at Georgetown University Law Center, was formerly Chairman of the Anne Arundel County (Maryland) Ethics Commission, and has chaired committees and served in other capacities in the D.C. Bar’s Taxation Section and the American Bar Association, Section of Taxation.
Christopher S. Rizek is a member of the law firm of Caplin & Drysdale, Chartered, in Washington, D.C. He formerly …
Pete Wilson is a Managing Director with RSM McGladrey’s National Tax practice and a partner in McGladrey & Pullen, LLP. He is responsible for quality assurance, risk management, and professional standards for the firms’ $400+ million tax practice.
Pete regularly advises RSM McGladrey tax professionals concerning professional standards, quality assurance, and risk management matters. He also consults with tax professionals from the 96 independent CPA firms that are members of the RSM McGladrey Network.
Pete is licensed as a Certified Public Accountant in New York and North Carolina and is admitted to the bar in New York, Massachusetts (inactive), and North Carolina. He is a member of the AICPA and the American Bar Association (Tax Section and Standards of Tax Practice Committee).
Pete Wilson is a Managing Director with RSM McGladrey’s National Tax practice and a partner in McGladrey & Pullen, LLP. …
Mr. Bernhardt is a former trial attorney in the IRS Office of Chief Counsel who practices in the area of federal tax controversies and federal tax litigation. He represents taxpayers, charitable organizations, private foundations, and other tax-exempt and nonprofit organizations before the IRS and Department of Justice in a variety of administrative matters, including audit examinations, administrative appeals, criminal investigations, and refund claims. He also appears on their behalf in federal courts, including the U.S. Court of Federal Claims, the U.S. Tax Court, U.S. District Courts, and U.S. Courts of Appeals.
He also advises charities, private foundations, and other tax-exempt and nonprofit organizations on a variety of governance and tax matters. He has advised clients on issues such as entity formation, obtaining and maintaining tax exemptions, corporate governance, reclassifications, private inurement, intermediate sanctions, unrelated business income tax, tax reporting, tax disclosures, self-dealing, income distributions, investment restrictions, expenditure limitations, and related governance matters.
Mr. Bernhardt also has experience representing federal officials in disputes over their reappointment to office.
Mr. Bernhardt is a former trial attorney in the IRS Office of Chief Counsel who practices in the area of …
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