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Tax Issues for
Attorneys and Law
Firms
Kevan P. McLaughlin, Esq., LL.M
Attorney-Client Privilege
o Privilege holder is, or sought to be, a client;
o Communication was to made:
o To a member of ...
Record Keeping Requirements
Every person liable for any tax imposed
by this title, or for the collection thereof,
shall ke...
Record Keeping Requirements
(a) ... any person required to file a return of information with
respect to income, shall keep...
Record Keeping Requirements
IRC § 446(b)
Cohan v. Commissioner, 39 F.2d 540 (2d Cir.
1930)
IRC § 274(d)
Income Issues
o Unreported Income
o Deferral of Income
o Constructive Receipt
o Non-Cash Sources
o Cash Payments
Advanced Client Costs
oNet Fee Arrangements
oGross Fee Arrangements
oNon-Contingent Fee Cases
Worker Classification
oBehavioral Control
oFinancial Control
oType of Relationship
Worker Classification
Concerns
o Reciprocal State Employment Tax
Matters
o Section 530
o Trust Fund Recovery – IRC § 6672
...
Information Reporting
oForm 1099
o IRC § 6041
oTreas. Reg. § 1.6045-5
oForm 8300
o IRC § 6050I
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Tax Issues for Attorneys and Law Firms

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Attorneys and law firms are not immune from their own tax issues, but their tax issues are unique.

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Tax Issues for Attorneys and Law Firms

  1. 1. S Tax Issues for Attorneys and Law Firms Kevan P. McLaughlin, Esq., LL.M
  2. 2. Attorney-Client Privilege o Privilege holder is, or sought to be, a client; o Communication was to made: o To a member of the bar or subordinate, and o Made in connection with them acting as a lawyer, o Relates to fact attorney of which attorney was informed: o By the client o Without the presence of strangers o For the purpose of securing primarily either: o An opinion of law, o Legal services, or o Assistance in some legal proceeding, and not o For the purpose of committing a crime or tort, and o The privilege has been o Claimed, and o Not waived by the client. o See also IRC § 7525
  3. 3. Record Keeping Requirements Every person liable for any tax imposed by this title, or for the collection thereof, shall keep such records, render such statements, make such returns, and comply with such rules and regulations as the Secretary may from time to time prescribe.
  4. 4. Record Keeping Requirements (a) ... any person required to file a return of information with respect to income, shall keep such permanent books of account or records, including inventories, as are sufficient to establish the amount of gross income, deductions, credits, or other matters required to be shown by such person in any return of such tax or information. (e) The books or records required by this section shall be kept at all times available for inspection by authorized internal revenue officers or employees, and shall be retained so long as the contents thereof may become material in the administration of any internal revenue law. Treas. Reg. § 1.6001-1
  5. 5. Record Keeping Requirements IRC § 446(b) Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930) IRC § 274(d)
  6. 6. Income Issues o Unreported Income o Deferral of Income o Constructive Receipt o Non-Cash Sources o Cash Payments
  7. 7. Advanced Client Costs oNet Fee Arrangements oGross Fee Arrangements oNon-Contingent Fee Cases
  8. 8. Worker Classification oBehavioral Control oFinancial Control oType of Relationship
  9. 9. Worker Classification Concerns o Reciprocal State Employment Tax Matters o Section 530 o Trust Fund Recovery – IRC § 6672 o Voluntary Worker Classification Settlement Program (VCSP)
  10. 10. Information Reporting oForm 1099 o IRC § 6041 oTreas. Reg. § 1.6045-5 oForm 8300 o IRC § 6050I

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