Mobile Edition


How to Write a Tax Advisory Opinion Letter (ACHWTA17)

 
Date:Thursday, December 14, 2017
Time:3:00 PM - 7:00 PM
(Registration at 2:30 PM)
Facility:Webcast or Webinar, Online
CPE Credit:4.0 Technical Business
Instructor: David R. Jenkins
Vendor:ACPEN
Course Level:Intermediate
Early Bird Price:$129.00 FICPA Members, $159.00 Non-Members

Description:

Financial accounting is historic in perspective while managerial accounting is prospective in perspective. Similarly, tax return preparation is historic in perspective while tax planning is prospective in perspective. The tax advisory opinion letter serves the tax planning function by documenting the current state of law, regulations, administrative rulings, and decisional law in support of planned activities. The tax advisory opinion letter set forth in this webcast borrows its design from well established appellate brief writing practices.

 

Syllabus

Lesson 1.

Introduction

Lesson 2.

Tax Advisory Opinion Letter - Introduction

Lesson 3.

Tax Advisory Opinion Letter - Facts

Lesson 4

Tax Advisory Opinion Letter - Issues

Lesson 5.

Tax Advisory Opinion Letter - Discussion

Lesson 6

Tax Advisory Opinion Letter – Conclusion

Lesson 7

Tax Advisory Opinion Letter – Acknowledgement of Factual Verity

 

  • This course is approved by the IRS. The submission of a completed request form, found under the materials tab, is required for credit.



    Objectives:

  • Recognize how to correctly frame authority, credentials, and empowerment to author a tax advisory opinion letter  

  • Recognize how to correctly identify and frame material and essential factual averments necessary to fulfill the elements of foreseeable tax positions  

  • Recognize to correctly identify and frame material and essential issues engendered by foreseeable tax positions  

  • Recognize how to correctly discuss material and essential tax position arguments in support of the recognized issues  

  • Recognize how to correctly frame client factual verity acknowledgment



    Major Topics:

  • Authority to author a tax advisory opinion letter  

  • Credibility required to author a tax advisory opinion letter  

  • Avoiding the unlawful practice of law when authoring a tax advisory opinion letter  

  • Limiting factual averments to essential and necessary statements  

  • Framing tax advisory opinion letter issues  

  • Declaring issue resolution in the affirmative based on tax law conclusions  

  • Obtaining the client’s signature attesting to the accuracy of the factual averments



    Who Should Attend:
    *CPAs *Attorneys *Enrolled Agents

    Prerequisite:
    This webcast is an intermediate continuing education webcast. It is assumed the webcast participant has fundamental familiarity with tax research

    Advanced Preparation:
    None

    Session/Options

    If listed below, select the appropriate sessions or options to continue with your purchase.

    Registration Status: CLOSED - Online registration for this course is now closed. Please contact the Member Service Center at (800) 342-3197 if you wish to inquire about registering.