Scott Michel Addresses Ethical Issues in International Tax at IFA Winter International Tax Conference
International tax practitioners frequently grapple with ethical questions arising from representing clients in both tax planning and tax controversy matters. These issues include conflicts of interest, due diligence, questions over privilege and confidentiality, tax return reporting and disclosure matters, and advice to taxpayers who have engaged in non-compliance. Such questions raise issues both under the applicable disciplinary rules and IRS Circular 230. The panelists will discuss the landscape of ethical rules and work through a series of hypotheticals that frame the relevant issues and provide practical and instructive guidance.