Circular 230
Circular 230 is now effective. Its impact on estate planners, especially those who provide gift and estate tax advice, is problematic. As CCH Tax Briefing: Controversial Circular 230 Rules of Practice Now Effective, June 22, 2005, states:
Tax practitioners are facing a brave new world that requires them to comply with rules of practice for tax shelter opinions, and they’re not happy about it. They believe the Circular 230 regs are vague and overly broad. To avoid the reach of the new law, firms are developing disclaimers, which they intend to include with most, if not all, communications sent outside the firm.
The cited publication contains an extensive discussion of Circular 230 along with a sample client letter.
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