The Circular 230 Deskbook: Related Penalties, Reportable Transactions, Working Forms is an essential compliance resource for every tax professional who practices before the IRS, helping practitioners comply with complex Circular 230 amendments more easily while avoiding costly penalties and sanctions. This practice guide shows you how to meet mandated duties applicable to six types of covered opinions, comply with critical requirements for written tax advice, carry out prescribed duties when advising in preparation of tax returns, satisfy reporting/list maintenance rules for six types of reportable transactions, and qualify for ”safe harbors” that free you from burdensome Circular standards, exploit proven defenses against the Code’s section 6662 penalties, and avoid common errors that can trigger these 6662 penalties.

The new release includes the following updates:

• Chapter 1, Deference: When the Court Must Yield to the Government’s Interpretation, discusses a D.C. Circuit Court decision ruling in favor of the taxpayer after noting that the regulation in question was amenable to both a pro-taxpayer and pro-IRS reading and that the IRS itself had previously agreed with the taxpayer’s reading.
• Chapter 4, Circular 230, advises that the IRS and Treasury issued proposed amendments to various sections of the Circular in late December 2024. The proposal is driven, in large part, by losses the IRS sustained in two cases (Loving v. IRS and Ridgely v. Lew) limiting its authority under the statute that authorizes the promulgation of the Circular.

The Table of Authorities have also been updated.

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Langer on Practical International Tax Planning provides current knowledge and expert advice attorneys need to help clients capitalize on ripe tax havens and financial centers. The book provides up-to-date information on the legal, tax, business, financial, social, political, technological, geographical, and regional factors to consider when developing and implementing customized planning strategies for clients. Packed with case studies, the book guides readers on how to select the right territories for each client, deploy the right instruments within each territory to eliminate, reduce, or defer taxes, avoid planning missteps that trigger tax problems, use local contacts to open doors to tax havens, and respond effectively to changing tax planning situations in specific havens and financial centers.

The latest release includes updates on:

• Chapter 2 discusses the Tax Court holding that a partnership was engaged in the conduct of a U.S. trade or business based on the activities of its asset manager, and was also a “dealer in securities” subject to the mark-to-market accounting rules of section 475.
• Chapter 5 talks about a case in which the Tax Court noted that the scope of section 904(f)(3) allows taxpayers to offset U.S. tax liability with a foreign tax credit, but does not cap the taxpayer’s gain to the amount of corresponding loss.
• Chapter 18 explains an IRS legal memorandum concluding that restricted stock units compensating an employee for work performed for both a U.S. employer and its controlled foreign corporation are wages subject to federal income tax withholding, but only grants for work performed in the United States will be subject to FICA.
• Chapter 26 examines what it means to “willfully” (or “non-willfully”) file a false income tax return or fail to report foreign bank accounts.

Order a print copy today.

PLI PLUS subscribers can access this title through their subscription.