1(a)(7), a client may request that the CPA disclose
the client's confidential information to a designated person or entity without providing written permission for the disclosure.
The third provision generally restricts an adviser from advertising any graph, chart, formula or other device that consumers can use to determine when to make investment decisions, unless it prominently discloses
the device's limitations and difficulties in its use.
Although the IRS acknowledged that if the taxpayer had adequately disclosed the gift, the SOL would have expired, it continued to maintain that the taxpayer did not properly disclose
the gift under Sec.
The IRM's suggested use of contractual provisions to protect trade secrets does not adequately protect the taxpayer if the independent expert discloses
or utilizes such trade secrets for purposes other than the IRS's examination and any subsequent litigation.
In 1980, FDA issued a regulation that would have required manufacturers to disclose
juice content prominently on labels of diluted juices.
Most privacy legislation requires that, upon an individual's request, an organization must supply any personal data it possesses and reveal how it uses and discloses
As recently stated by Deputy Assistant Treasury Secretary for Tax Policy, Pamela Olsen, the IRS believes that "disclosure really matters" and that "penalties can apply if the taxpayer does not act in good faith in its dealings with the IRS, and the failure to disclose
the transaction shows a lack of good faith.
Using this as a guide, the conflicts of interest disclosure checklist on Page 12 may provide a way to disclose
information to a client and permit the CPA to continue to provide services.
Tippees are people with no fiduciary obligation to the company to whom an insider discloses
material nonpublic information.
Therefore, if a taxpayer reports a transfer on a gift tax return that he believes to be a completed gift but later turns out to be an incomplete gift, and he discloses
the transfer as required under the regulation, the transfer would be included in the donor's gross estate, only to the extent that a completed gift would be so included.
Caution: If a non-CEP taxpayer is contacted by the Service for an examination before the taxpayer discloses
a given position, it is too late to disclose
on a qualified amended return.
If no tax return need otherwise be filed, the regulations still require filing an information return that discloses
the use of a treaty.