eCourse
Unearthing Old Skeletons: The Impact of Circular 230 and Correction of Tax Positions
Contains material from Aug 2023
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Includes: Video Audio Slides
- Total Credit Hours:
- 1.00 | 1.00 ethics
- Credit Info
- TX, CA
- Specialization: Tax Law
- TX MCLE credit expires: 8/31/2024
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Tom Greenaway, Timothy J. McCormally
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Session 1
—59 mins
1.00 | 1.00 ethics
Unearthing Old Skeletons (Aug 2023)
University officials sometimes discover that a tax position the school has taken may be incorrect. For example, a school may have treated the value of the President’s residence as excludable under section 119 when facts indicate the contrary. Gain insight on how to deal with such situations, including the pros and cons of getting a third-party tax opinion and the different comfort levels for tax opinions (reasonable basis, more likely than not, etc.). If the tax position is wrong, what are the school’s options? Do you fix it prospectively or is retroactive correction or even a voluntary disclosure required or recommended? Discuss the impact of Circular 230 (the IRS’s rules of professional conduct).
Originally presented: Jun 2023 Higher Education Taxation Institute
Tom Greenaway,
KPMG LLP - Boston, MA
Timothy J. McCormally,
Internal Revenue Service - Washington, DC