Course: Tax - difficult situations and how to resolve them

Topics Include:

  • Rectification - what is and is not possible
  • Amending returns
  • Late filed designations and elections
  • Notices of objection
  • Appeals to the tax court
  • Fairness applications
  • Problems discovered after acquiring a client from a former accountant
  • Voluntary disclosures
  • Avoiding problems: price adjustment clauses, advance rulings, technical interpretations, carefully prepared working papers, internal memoranda