Article Abstract:
The tax reform debate centers on policies to reward savings such as switching from an income tax to a consumption tax system, and on base-broadening policies, such as the flat tax, aimed at eliminating deductions, loopholes, and exceptions. The tax reform push is driven by anti-government feelings, a desire for tax simplification, and concerns about the deficit. Tax practitioners can add thoughtful recommendations and insights to the debate, while assessing the impact of proposed legislation on clients' pending transactions.
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Article Abstract:
The IRS is releasing Litigation Guideline Memoranda under the Freedom of Information Act, but the insights these documents provide appears limited because much information has been redacted under the work-product doctrine. The memoranda available focus on international, criminal, disclosure, tax-exempt and pension issues. Memoranda on litigation and field service are forthcoming. Practitioners may find some of these documents helpful to the extent that they identity issues of importance to the IRS.
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Article Abstract:
The tax practitioner-confidential communications privilege authorized by the IRS Restructuring and Reform Act of 1998 is narrow in scope and uncertain in many respects. The privilege is narrower than the attorney-client privilege by not being applicable to criminal proceedings, by being applicable only to tax advice, by being assertable only in specified tax proceedings, and by not being applicable to written tax shelter-related communications.
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