TAX
“[ A ] ll tax practitioners should consider adding [ The Circular 230 Deskbook ] to their collections ... ”
— The Journal of the American Taxation Association
THE CIRCULAR 230 DESKBOOK
• RELATED PENALTIES
• REPORTABLE TRANSACTIONS
• WORKING FORMS
Jonathan G . Blattmachr ( Retired , Milbank , Tweed , Hadley & McCloy LLP ) and Mitchell M . Gans ( Hofstra University )
This Deskbook , written by professors and practitioners with significant experience , offers important practice tips and compliance guidelines for anyone who practices before the IRS . Readers can access sample disclaimers , memoranda , and checklists when encountering key matter milestones , along with important IRS forms necessary for effective practice . In addition , readers will learn important defenses and safe harbors for avoiding IRS penalties and compliance missteps .
Stay ahead of practice developments with PLI ’ s Upkeep Service .
1 looseleaf volume , 1,098 pages , $ 663 , Item # 9134 , ISBN 978-1-4024-0754-3 , Updated annually or as needed
CONTENTS
1 Deference : When the Court Must Yield to the Government ’ s Interpretation 2 Selected Penalties 3 Reporting and List Maintenance
Requirements 4 Circular 230
Appendices A Circular No . 230 B Circular 230 Addendum
( July 2002 ) C Circular 230 ( 1921 Version ) D Circular 230 Decision Tree E Chart for Compliance with Circular 230 § 10.35 for “ Covered Opinions ” F Circular 230 Flowchart G Chart : Reportable Transactions H Checklist for Covered Opinions and Other Written Advice About Federal Tax Issues
I Analysis of Certain Court-Made or Judicial Tax Doctrines J AICPA Bylaws : Section 730 K KPMG Indictment L IRS Form 706 M IRS Schedule M-3 ( Form 1120 ) N IRS Form 2848 O IRS Form 8886 P [ Reserved ] Q General Disclaimer About Circular 230 for Use in General Memorandum About Tax Law Matters
R Sample Disclaimers
S Sample Framework of a Circular 230 Covered Opinion
T Sample Memorandum of Written Advice Not Constituting a Covered Opinion U 18 U . S . C . § 207 V Proposed Regulations for Practitioners Rendering Municipal Bond Opinions
W Summary Order : Long-Term Capital Holdings , LP v . United States
X Selected Internal Revenue Code Sections and Treasury Regulations Regarding Penalties
Y Application for Enrollment to Practice Before the Internal Revenue Service Z IRS Form 8921 AA IRS Forms 8275 and 8275R BB IRS Notices 2007-54 , 2008-11 , 2008-12 , 2008-13 , 2008-14 , 2010-33
CC Practitioner Penalties Under Circular 230 § 10.34 DD Preparer Penalties Under
EE
IRC § 6694 Director , Office of Professional Responsibility v . Sykes , Complaint 2006-1 FF Notice 2009-55 GG Notice 2009-59
Bibliography Table of Authorities Index
TRANSFER PRICING ANSWER BOOK Edited by David B . Blair ( Eversheds Sutherland ( US ) LLP )
Created by a practitioner with more than two decades of experience , this title walks executives at MNEs and their counsel through tactics for mitigating tax liability and costs around intercompany transactions .
In a reader-friendly question-and-answer format , corporate counsel , tax practitioners , and MNE leaders will find thorough and non-technical discussion of court-tested strategies . This approach helps distill often complex transfer pricing topics into an easy-to-follow format for any reader , regardless of their experience or familiarity with taxation or transfer pricing issues .
Track transfer pricing legal developments with PLI ’ s Upkeep Service .
1 softbound volume or digital , 720 pages , $ 276 , Item # 325757 , ISBN 978-1-4024-4288-9 , Published annually or as needed
CONTENTS
1 The Transfer Pricing Challenge 2 The Players : The IRS and Foreign Tax Authorities , the OECD , and the Tax Treaty Network 3 The U . S . Legal Framework 4 Conducting a Transfer Pricing Analysis 5 Overview of Transfer Pricing Methodologies : The Best Method Rule , Transaction-Based Methods , and Profit-Based Methods 6 Identification of Controlled Transactions 7 Recordkeeping and Reporting Obligations for U . S .
Taxpayers and Their Foreign Affiliates 8 Penalties for Transfer Pricing Adjustments and
Contemporaneous Documentation Requirements 9 Transfer Pricing Planning and Taxpayers ’ Affirmative Use of
Section 482 10 Manufacturing and Distribution of Goods 11 Provision of Services 12 Intangible Property : Discussion of Issues Arising from the Development and Transfer of Intangible Property , Including Licensing , Contract R & D , and Cost Sharing Models
13 Cost Sharing Arrangements , Including Their Interrelationship with Intangibles Transfers 14 Loans and Rentals 15 Strategic Considerations in Transfer Pricing Planning That
Drive Controversy Positions 16 Advance Pricing Agreements 17 Handling Transfer Pricing Audits by the IRS 18 Considerations When Settling Transfer Pricing Disputes 19 Competent Authority 20 Litigating a Transfer Pricing Case 21 Coordination with Customs Valuations 22 Financial Accounting for Transfer Pricing Exposures 23 OECD Efforts to Eliminate Base Erosion and Profit Shifting
( BEPS ) and the Two-Pillar Inclusive Framework
Index
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