This notification is to inform you of how our correspondence with clients, including e-mail messages, is affected by IRS regulations governing tax practitioners.
IRS Circular 230 requires us to add certain standard language to many of our letters, memos, e-mails, and other correspondence concerning federal tax matters, unless we are willing to undertake extensive analysis of the facts underlying a transaction and legal authorities that address the tax treatment of the transaction. This includes written advice concerning planning related to, or the application of, any federal tax on the business or personal affairs of our clients.
While the specific wording may vary depending on the circumstances, absent the thorough analysis of the facts, you can expect written advice from our firm to contain language similar to the following:
Circular 230 Disclosure
As required by United States Treasury Regulations, you are hereby notified that this communication is not intended by the sender to be used, and it cannot be used, for the purpose of avoiding any federal tax penalties that may be imposed under United States federal tax laws, or for promoting, marketing or recommending to another person, any tax related matter.
These rules require such notices to be prominently disclosed and readily apparent to the reader. The notice must be in a separate section of the correspondence and the typeface used must be at least the same size as the typeface used in any discussion of facts or law.
Be assured that this policy does not reflect any decrease in the quality of our services or the amount of thought we put into our correspondence with our clients. We have adopted this policy as part of our effort to provide distinct and concise answers to normal tax matters without having to undertake extensive analysis of the facts, thus increasing fees due to having spent considerable time to further investigate and document matters not required for normal discussion of most tax issues. Without such a disclaimer, additional fees would often be required for us to fully ascertain and analyze factual matters underlying the advice.
In situations where we believe that the circumstances warrant the increased fee attributable to a communication that may provide clients with protection from the imposition of penalties, we will discuss the matter with a client directly. In the event a client desires a written communication upon which to rely for protection from the imposition of penalties, we encourage clients in such circumstances to discuss the matter with us.