Bryan C. Skarlatos and Megan L. Brackney published, "New Guidance Provides Limited Relief from Penalties for Failure to Comply with List Maintenance Requests"

By Bryan C. Skarlatos and Megan L. Brackney

Imagine you are a partner at an accounting fi rm and you discover that, several years ago, one of your partners provided advice to a few clients regarding a type of retirement plan that was a reportable transaction. After auditing the taxpayers, the IRS is now focusing on your fi rm as a possible material advisor and has requested the fi rm to provide a list with respect to all reportable transactions for which it was a material advisor. Failure to provide the requested information within 20 days of the request can result in crushing penalties of as much as $10,000 per day!

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