A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.

This volume considers the wide array of sources that govern tax practice by lawyers and accountants, including IRS Circular 230, ethical principles and practice rules specific to each profession and a panoply of practice-related provisions in the Internal Revenue Code. There have been a number of important cases since the first edition was published, ranging from limitations on the IRS's authority to regulate tax practice to the applicability of privilege principles in the context tax work product. The second edition is fully updated to reflect recent developments, and includes many new problems.

Ethical Problems in Federal Tax Practice provides clear explanations of the relevant rules and regulations that apply to tax lawyers and organizes the materials by the various functions a lawyer serves: litigator, advisor and counselor. This is the only casebook currently available for law courses on professional responsibility in tax practice. Look for these key features in the new edition: New chapter on international tax practice Effect of technology innovations, e.g., email and social media, on ethical tax practice, including issues such as ethical advertising and solicitation, outsourcing and fee sharing Changes to Circular 230, the document governing practice before the IRS