19 Jul 2022
Stop! You Can’t Disclose my Taxpayer Information!
The Internal Revenue Code (IRC) provides for the confidentiality of taxpayer tax returns and return information. In general, employees and officers of the federal government, certain employees and officers of states or state and local agencies, and other persons with access to such returns or return information are required to keep tax return and return information confidential unless authorized by the IRC. This practice note contains a diagram breaking down the factors to consider and the questions to ask in determining whether there is an I.R.C. § 6103 violation and, if so, whether a taxpayer may have a civil action against the United States under I.R.C. § 7431 for damages.
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See how, speaking of confidentiality, the doctrine of attorney-client privilege affects tax matters. This practice notes reviews attorney-client privilege fundamentals, application of the privilege to accountants and other nonlawyers, and how to assert―and even waive―the privilege.
Practical Guidance Updates
Featuring the latest updates from your Practical Guidance account.
- Tax Key Legal Developments Tracker (Federal)
- Stay informed on new developments:
- Business Entities. IRS provides the exclusive procedures for requesting a determination under I.R.C. § 4672(a)(2)that a substance be added to or removed from the list of taxable substances under I.R.C. § 4672(a). Rev. Proc. 2022-26.
- Individual Income Tax. Treasury and IRS issue proposed regulations amending existing regulations issued under I.R.C. § 2053, providing guidance on the proper use of present-value principles in determining the amount deductible by an estate for funeral expenses, administration expenses, and certain claims against the estate. 87 Fed. Reg. 38331 (June 28, 2022).
- Document alerts allow you to stay current on legal developments that affect your practice. Find out how to set up your document alerts.
- Check out the new Practical Guidance Author Center! Learn about the 1500+ leading attorney authors contributing to our 21 practice areas, and find out how you can Become a Practical Guidance Author.
- Share fundamental guidance with your firm’s summer associates to help them sharpen their research and writing skills, get the inside scoop on summer associate survival, and hit the ground running in the tax practice area. Review the resources in the Summer Associate Resource Kit: Tax.
- The Practical Guidance Journal Summer 2022 Edition features guidance on wage and hour issues related to remote and hybrid work.
- Listen Up! Practical Guidance Podcast: Labor and Employment Series Episode 1: Recruiting and Retaining Employees in the Current Hiring Landscape. Are you confronting hiring and retention issues with the next generation work force? Push play and listen to the newly released Practical Guidance podcast, “Recruiting and Retaining Employees in the Current Hiring Landscape,” with Mintz L&E partner, Jennifer B. Rubin.
- New and Recently Updated Practical Guidance Content
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- Outbound Taxation Fundamentals
- Foreign Currency Transactions and Tax Consequences
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- EPCRS Plan Correction Checklist
- KPMG Report: Tax Information Reporting on Crypto-Assets
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