Article: New Circular 230 regulations impose strict standards for tax practitioners.

I. Introduction

On December 17, 2004, the U.S. Department of the Treasury published final regulations amending the tax shelter provisions of Circular 230, which imposes duties on practitioners representing taxpayers before the Internal Revenue Service. These revisions provide (1) "aspirational" practice standards for tax advisers, (2) mandatory requirements for "covered opinions," and (3) new practice standards for all other written tax advice. (1)

These regulations are the most recent development in a continuing effort to deter abusive tax shelter opinions. As far back as 1980, the Treasury Department characterized abusive tax shelters as one of the ...

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