The beneficial ownership reporting requirement established by the Corporate Transparency Act has created a fair amount of chaos concerning whether providing reporting services to clients is the unauthorized practice of law (UPL). While some state bar associations have come down on one side or the other as to whether certain types of reporting are UPL, the Treasury offers no clear guidance. What the IRS has made clear recently is that Circular 230 ethical obligations extend to matters beyond what the Loving case determined was “practice before the IRS.”
Tax Tales I Let Slip in 2025: From Whistleblowers to Easement Woes and Beyond
Peter J Reilly CPA
One of my greatest frustrations as a tax writer is that I just don’t have the time to cover everything that I notice. Early in my blogging career, when I was younger and had more energy, I set myself on a Monday, Wednesday, Friday schedule like the college professors I envied. Even that did not keep up with everything I noticed, so periodically I would do a post that had short blurbs about interesting things I didn’t dig further on. Here is an example from 2010 of a post that covers an entity not considered a church by the IRS, S corp shareholder basis issues, definition of alimony and two Chief Counsel Advices on TEFRA issues. So here are some things for 2025, that I opened a file on but never managed to make an article with.
