The Many Repercussions of Section 6694
Overview:
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.
Agenda:
- 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 …
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 …
Course Level:
Intermediate
Advance Preparation:
Print and review course materials
Method of Presentation:
On-demand Webcast (CLE)
Prerequisite:
NONE
Course Code:
83758
Total Credits:
2.0 CLE
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SPEAKERS' FIRMS:
About Caplin & Drysdale
Website: https://www.capdale.com/
About RSM McGladrey, Inc.
Website: https://www.rsmmcgladrey.com/
About McGuireWoods LLP
Website: https://www.mcguirewoods.com/