Preparing IRS Letter Rulings, Technical Advice Requests, Change of Accounting Requests, Tax Opinions, and more
By: Stuart Sobel & Steven Mopsick
Tax planning is “fire prevention” and tax preparation is “arson investigation”. The typical tax practitioner focuses on the preparation of last year’s tax returns. They are more reactive than proactive. Taxpayers worry about how the IRS will react to their handling of transactions and the related tax reporting. The IRS can assert egregious penalties for improper tax filings. Is it possible to find out what the IRS position is on a proposed transaction? Can you go forth with an event and feel comfortable to know that the IRS will accept your interpretation of the law and not subject you or your client to an examination or long challenging tax controversy events?
The answer is yes to all the questions above. The IRS has procedures that expedite action and secure concurrence with your interpretations of the law. This unique course will go into detail into the methods that can be utilized by taxpayers and their representatives. Stu Sobel and Steven Mopsick have 90+ years of tax expertise working for the IRS in the examination function, district counsel, and in high level management as well as representing clients in private practice. They have taught at the college level and also the author of four books on taxation which have been used to train thousands of tax professionals worldwide.
The course will go into detail into very challenging techniques to defend and support clients. If you wish to master a very sophisticated way of planning for the future and avoiding chaos later on, this course is for you.
Topics covered during the course are as follows:
- Preparing a binding letter ruling request for future transactions
- How to ask the IRS their technical interpretation of the tax ramifications of some action in writing
- Preparing a request for a change of accounting method or finding out when one is not necessary
- Understanding the differences in preparing different types of opinions for taxpayers in accordance with IRS Circular 230
- Navigating the IRS website for relevant information
- How to contest an adversarial response from the IRS
- Understand proactive approaches to gain IRS insight in transactions
- Utilize varying techniques to defend a client
- Learn how to comply with Circular 230 guidelines relating to writing tax opinions
Prerequisites: Experience in representing clients in tax controversy matters
NASBA & IRS Field of Study: Taxes
CPE Credit: 1 hour