TREASURY, IRS MOVE TO CURB OPINION LETTERS, IMPROVE DISCLOSURE: The Treasury Department and the Internal Revenue Service announced measures that are expected to have a chilling effect on the use of opinion letters that are drafted by accountants and attorneys, amid other measures aimed at increasing the transparency and disclosure of information to the IRS.

The agencies announced proposed changes to Circular 230 that set out specific requirements for tax opinions provided by attorneys and accountants. The proposed changes describe best practices for tax advisors and call on professional services firms to put in place procedures that are consistent with the best practices. The changes would obligate tax advisors to inform clients explicitly about what protections, if any, an opinion letter provides to the client.

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