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Live Webcast Replay

How to Write a Tax Advisory Opinion Letter


Total Credits: 4 including 4 Taxes - Technical

Average Rating:
   15
Categories:
ACPEN Industry Institute |  ACPEN Tax Institute |  IRS Approved |  Tax
Speaker:
David Randall Jenkins, Ph.D.
Course Levels:
Intermediate
Duration:
4 Hours
Product Type:
Live Webcast Replay
License:

Dates


Description

Financial accounting is historic in perspective while managerial accounting is prospective in perspective. Similarly, tax return preparation is historic in perspective while tax planning is prospective in perspective. The tax advisory opinion letter serves the tax planning function by documenting the current state of law, regulations, administrative rulings, and decisional law in support of planned activities. The tax advisory opinion letter set forth in this webcast borrows its design from well established appellate brief writing practices.

This webcast involves Section 179 depreciation expense at the partnership level in a startup operation. Although not incorporated into this webcast, Dr. Jenkins wants to share his paper, "Why Section 179(b)(3)(A)'s Business Income Limitation Does Not Apply to Partnerships or S Corporations." The paper is currently in peer review at a university tax journal. Also, the ACPEN/BPN webcast based on this paper will be first aired during the week of September 25-29, 2017. Please be sure to look for that announcement and register for the webcast.

Syllabus

Lesson 1.

Introduction

Lesson 2.

Tax Advisory Opinion Letter - Introduction

Lesson 3.

Tax Advisory Opinion Letter - Facts

Lesson 4

Tax Advisory Opinion Letter - Issues

Lesson 5.

Tax Advisory Opinion Letter - Discussion

Lesson 6

Tax Advisory Opinion Letter – Conclusion

Lesson 7

Tax Advisory Opinion Letter – Acknowledgement of Factual Verity

 

Basic Course Information

Learning Objectives

*Recognize how to correctly frame authority, credentials, and empowerment to author a tax advisory opinion letter  

*Recognize how to correctly identify and frame material and essential factual averments necessary to fulfill the elements of foreseeable tax positions  

*Recognize to correctly identify and frame material and essential issues engendered by foreseeable tax positions  

*Recognize how to correctly discuss material and essential tax position arguments in support of the recognized issues  

*Recognize how to correctly frame client factual verity acknowledgment


Major Subjects

*Authority to author a tax advisory opinion letter  

*Credibility required to author a tax advisory opinion letter  

*Avoiding the unlawful practice of law when authoring a tax advisory opinion letter  

*Limiting factual averments to essential and necessary statements  

*Framing tax advisory opinion letter issues  

*Declaring issue resolution in the affirmative based on tax law conclusions  

*Obtaining the client’s signature attesting to the accuracy of the factual averments


Course Materials

Speaker

David Randall Jenkins, Ph.D.'s Profile

David Randall Jenkins, Ph.D. Related Seminars and Products


David Randall Jenkins, Ph.D., received his doctorate in accounting and a master’s in accounting with an emphasis in tax from the University of Arizona. He has taught financial, managerial, and tax accounting courses at both the graduate and undergraduate levels. Dr. Jenkins is an AACSB academically qualified business school and tax professor owing to his peer reviewed journal article publications. His company, Algorithm LLC (algorithm-llc.com), is an IRS Approved Continuing Education Provider.  Dr. Jenkins may be contacted at tucjenkins@aol.com.


Additional Info

Basic Course Information

Original Recording Date

04/25/2016


Date Added to Catalog

04/13/2016


Prerequisites

This webcast is an intermediate continuing education webcast.  

It is assumed the webcast participant has fundamental familiarity with tax research


Advanced Preparation

None


Designed For

*CPAs  

*Attorneys  

*Enrolled Agents  

 


Course Developer

***____***


Yellow Book

No


Additional Information

Instructional Delivery Method

Group Internet Based


Complaint Resolution Policy

Please contact Anne Taylor for any complaints.  anne.taylor@acpen.com(972-377-8199).


Official Registry Statement

Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org


Refund/Cancellation Policy

Please contact the ACPEN help desk 1-877-602-9877 or help@acpen.com if you wish to cancel your attendance for a previously purchased webcast and are requesting a refund or transfer. 


Course Registration Requirements

Online Registration


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Overall:      4.2

Total Reviews: 15