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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.
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 practioner 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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