What is IRS Circular 230?
The Treasury Department and the Internal Revenue Service have been engaged in an effort to curb abusive tax shelters. As part of this effort, they have issued final regulations under IRS Circular 230 "… to restore, promote, and maintain the public's confidence in those individuals and firms …" who act as tax advisors.
This is an explanation of how our correspondence with you (including e-mails) will be affected by new IRS regulations governing tax practitioners.
The new rules in effect require us to add certain standard language to many of our letters, memos, e-mails, and other correspondence concerning federal tax matters. You have probably already seen similar language on written communications from your own professional legal or tax advisers. Although the specific wording may vary depending on the circumstances, you can expect to see notices similar to the following:
IRS CIRCULAR 230 NOTICE: To the extent that this message or any attachment concerns tax matters, it is not intended to be used and cannot be used by a taxpayer for the purpose of avoiding penalties that may be imposed by law.
The new rules require such notices to be "prominently disclosed," i.e., "readily apparent" to the reader. The notice must be in a separate section (but not in a footnote) of the correspondence. Also, "fine-print" notices won't work. The typeface used must be at least the same size as the typeface used in any discussion of facts or law.
A practitioner who fails to satisfy the requirement of the new rules risks censure, disbarment and substantial penalties.
Please be assured that this new policy does not reflect any decrease in the quality of our services or the amount of thought we put into our correspondence with you.
Please contact your Relationship Manager if you would like to receive more detailed information about the new rules or if you have any questions or concerns.
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