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IRS Proposes New Obligations for Tax Advisers

By Mark L. Silow, Esq.

With the stated purpose of restoring, promoting and maintaining the public's confidence in professionals providing tax advice, the Internal Revenue Service has issued proposed regulations that set forth “best practices” applicable to all tax advisers and mandatory requirements for advisers who provide certain tax shelter opinions.

These proposed regulations, issued on Dec. 29, 2003, apply to all tax advisers who practice before the IRS (eg, lawyers and accountants) but are not intended to alter or supplement other ethical standards applicable to practitioners (such as the Rules of Professional Conduct). The proposed regulations are to become effective on the date of publication of final regulations.

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