Course ID: ATP

Advanced Tax Practice


Code Sections 6694 and 7216. . . Treasury Circular 230 . . . Office of Professional Responsibility . . . AICPA Statements on Standards for Tax Services . . . every tax partner and senior manager faces a daunting array of new “guidance”. Rarely have tax and financial statement issues been so intertwined – and so likely to cause problems for tax practitioners. All CPAs must become familiar with risk analysis of tax return positions. This program explains what it takes to avoid penalties and keep fees reasonable.


LEARNING OBJECTIVES
  • Comply with Circular 230 and AICPA SSTS
  • Impose “Best Practices” in your tax practice
  • Identify “Uncertain Tax Return Positions” and test for “more likely than not” for FIN 48 compliance
  • Analyze tax return positions to determine degree of risk
  • Avoid penalties under IRC Sec. 6694 . . . how to use disclosure to avoid penalties
  • Avoid penalties under IRC Sec. 7216 . . . when to ask for client waiver of confidentiality
  • Determine whether a tax return position has “substantial authority” or a “reasonable basis”
  • How to make protective disclosure of tax return position with only “reasonable basis”

MAJOR TOPICS
  • Final Sec. 6694 regulations
  • “Best practices” and the value of engagement letters
  • Understanding required “levels of authority” for tax positions
  • Circular 230 (as amended June 2014) and AICPA Standards relating to tax return positions
  • Tax research, documentation and opinions
  • Case Studies in analysis of risk in tax return positions
  • Current developments in tax practice management and responsibilities of Tax Partners

DESIGNED FOR
Senior Tax Managers and Tax Partners

PREREQUISITES
Tax experience

COURSE PRODUCER
Nichols Patrick CPE, Inc

CPE CREDITS
8.0

LEVEL
Advanced

This course is available to be scheduled as:

Group Live
 

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