Megan L. Brackney (Procedurally Taxing): The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 2) (December 8, 2022)

Megan L. Brackney, of Kostelanetz LLP,  has made available for download her article “The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 2)”, published on the Procedurally Taxing blog. The abstract is as follows:

In yesterday’s post, I discussed some common penalties for failing to file foreign information returns and the practical and legal challenges associated with establishing that a client is entitled to relief from those penalties. Today we focus on how this penalty regime raises difficult ethical issues for practitioners who want to zealously represent their clients but also want to practice in a way that is consistent with their responsibilities and duties.

Click here to read Megan L. Brackney’s summary of “The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 2)”

Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.