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IRS Circular 230 Notice

Last Updated: December 15, 2024

IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

1. Purpose of This Notice

This notice is provided in accordance with IRS Circular 230, which sets forth standards for tax professionals who practice before the Internal Revenue Service. Circular 230 regulations require specific disclosures when providing written tax advice to ensure taxpayers understand the limitations and intended use of such information.

2. About IRS Circular 230

IRS Circular 230 (31 CFR Part 10) establishes the rules governing practice before the Internal Revenue Service. These rules apply to attorneys, certified public accountants, enrolled agents, enrolled actuaries, and other tax professionals who represent taxpayers before the IRS.

The regulations impose specific requirements for written tax advice to protect taxpayers and maintain the integrity of the tax system. All communications containing tax advice must include appropriate disclosures to inform recipients of the advice's intended purpose and limitations.

3. Nature of High-Income.org Services

3.1 Referral Platform

High-income.org operates as a professional matching and referral platform. We connect high-income individuals with qualified, independent tax professionals, including:

  • Tax attorneys licensed to practice law
  • Certified Public Accountants (CPAs)
  • Enrolled Agents (EAs)
  • Other qualified tax professionals

3.2 No Direct Tax Advice

High-income.org does not provide tax advice. Any tax advice you receive comes from the independent professionals you engage through our platform, not from high-income.org itself.

⚠️ Important Disclaimer

The information provided on high-income.org's website is for general informational and educational purposes only. It is not intended as specific tax, legal, or financial advice tailored to your individual circumstances. You should not rely on this information to make tax decisions without consulting qualified professionals.

4. Limitations on Website Content

4.1 General Information Only

All content on our website, including but not limited to:

  • Tax statistics and data
  • Information about deductions and tax strategies
  • Educational materials and resources
  • Case studies and examples
  • Blog posts and articles

...is provided for general informational purposes only and does not constitute tax advice specific to your situation.

4.2 Not Written to Avoid Penalties

Any information regarding tax matters on our website is not written with the intent of being used to avoid federal tax penalties. It cannot be used for that purpose.

4.3 Not for Promoting Transactions

Information on our website is not written to promote, market, or recommend any specific tax transaction, shelter, or planning structure to you or any other party.

5. Professional Engagements

5.1 Direct Professional Relationships

When you engage a tax professional through our platform, you enter into a direct professional relationship with that individual or firm. The professional will provide their own engagement letter, terms of service, and Circular 230 disclosures as appropriate.

5.2 Professional Standards

Tax professionals in our network are independently responsible for:

  • Complying with Circular 230 requirements
  • Maintaining their professional licenses and certifications
  • Providing appropriate disclosures in their communications
  • Following professional standards of practice
  • Carrying appropriate professional liability insurance

5.3 Covered Opinions

If your engaged professional provides a "covered opinion" (as defined in Circular 230 §10.35), that opinion must meet specific requirements regarding scope, research, documentation, and disclosure. Your professional will inform you if their advice constitutes a covered opinion.

6. Your Responsibilities

As a taxpayer seeking tax planning services, you should:

  • Engage Qualified Professionals: Work with licensed tax attorneys, CPAs, or enrolled agents for specific tax advice
  • Provide Complete Information: Share all relevant financial and tax information with your professional
  • Verify Credentials: Independently verify the credentials and standing of any professional you engage
  • Understand Advice Limitations: Ask questions about the scope and limitations of any advice you receive
  • Maintain Records: Keep thorough records of all tax advice and related documentation
  • Seek Multiple Opinions: Consider obtaining second opinions on significant tax matters

7. Tax Shelter and Reportable Transactions

7.1 Disclosure Requirements

Federal law requires disclosure of certain tax shelters and reportable transactions to the IRS. If your tax professional recommends a strategy that constitutes a reportable transaction, they must inform you of disclosure requirements.

7.2 Material Advisor Obligations

Tax professionals who act as "material advisors" (as defined in IRC §6111) have specific obligations to maintain lists and file informational returns with the IRS regarding certain transactions.

7.3 Our Position

High-income.org does not promote, market, or recommend tax shelters or reportable transactions. We connect you with professionals who can evaluate whether legitimate tax strategies are appropriate for your situation within the bounds of applicable law.

8. Penalties for Tax Underpayment

The Internal Revenue Code imposes various penalties for substantial underpayment of tax, including:

  • Accuracy-Related Penalties (IRC §6662): 20% penalty for substantial understatement of tax or negligence
  • Reportable Transaction Penalties (IRC §6662A): Enhanced penalties for reportable transactions
  • Substantial Understatement Penalty (IRC §6662(d)): Applies when understatement exceeds certain thresholds
  • Fraud Penalties (IRC §6663): 75% penalty for civil fraud

Proper professional guidance can help you avoid these penalties through compliant tax planning, but no communication on our website is intended to help you avoid penalties.

9. State and Local Tax Considerations

While Circular 230 applies to federal tax matters, many states have similar professional responsibility rules for tax practitioners. When engaging a professional through our platform for multi-state tax planning, ensure they:

  • Are licensed to practice in relevant jurisdictions
  • Understand state-specific tax laws and regulations
  • Comply with state professional responsibility standards
  • Provide appropriate state-specific disclosures

10. Changes to Circular 230

IRS Circular 230 regulations are subject to change. The Treasury Department and IRS periodically update these rules to address evolving tax practices and compliance concerns. We update this notice as needed to reflect current requirements, but you should consult with your tax professional about current standards.

11. Attorney-Client Privilege

Communications between you and a tax attorney you engage through our platform may be protected by attorney-client privilege. However:

  • Privilege applies to legal advice, not tax return preparation
  • Privilege can be waived by disclosure to third parties
  • Communications with CPAs and enrolled agents may have different privilege protections
  • Information shared with high-income.org before professional engagement may not be privileged

Discuss privilege considerations with your engaged professional to understand how it applies to your specific situation.

12. Standards of Practice

Tax professionals practicing before the IRS must comply with Circular 230 standards, including:

  • Competence: Professionals must be qualified and knowledgeable in matters they handle
  • Diligence: Exercise due diligence in preparing returns and representations
  • Due Diligence for Certain Credits and Deductions: Enhanced due diligence for specific tax benefits
  • Good Faith: Advise clients about all tax positions, not just favorable ones
  • Best Practices: Communicate clearly about terms of engagement and professional qualifications
  • Conflict of Interest: Identify and manage conflicts appropriately

13. Sanctions and Disciplinary Actions

The IRS Office of Professional Responsibility has authority to sanction tax professionals who violate Circular 230, including:

  • Censure (public or private reprimand)
  • Suspension from practice before the IRS
  • Disbarment from practice before the IRS
  • Monetary penalties

You can verify a professional's standing to practice before the IRS using the IRS Directory of Federal Tax Return Preparers with Credentials and Select Qualifications.

14. Questions and Concerns

If you have questions about:

  • The scope of advice you receive from a professional
  • Whether advice constitutes a "covered opinion"
  • Disclosure requirements for transactions
  • Professional standards and ethical obligations

Please direct these questions to your engaged tax professional, not to high-income.org.

For questions about this Circular 230 Notice or our referral services, contact:

Email: compliance@high-income.org
Subject Line: Circular 230 Inquiry

15. Additional Resources

For more information about Circular 230 and professional responsibility in tax practice, consult:

  • IRS Website: IRS.gov/tax-professionals/circular-230
  • Full Text: 31 CFR Part 10 (Code of Federal Regulations)
  • IRS Office of Professional Responsibility: Reports on disciplinary actions
  • Professional Organizations: American Bar Association Tax Section, AICPA, National Association of Enrolled Agents

Reminder: This notice is not exhaustive. For specific questions about your tax situation, federal tax advice, or professional standards, consult with a qualified tax attorney, CPA, or enrolled agent. High-income.org provides professional matching services only and does not provide tax or legal advice.

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IRS CIRCULAR 230 NOTICE: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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