DECLARATION OF CAROL A. CAMPBELL
|
|
- Estella Wells
- 5 years ago
- Views:
Transcription
1 USCA Case # Document # Filed: 02/25/2013 Page 1 of 11 DECLARATION OF CAROL A. CAMPBELL I, Carol A. Campbell, pursuant to the provisions of 28 U.S.C. 1746, declare as follows: I am the Director of the Return Preparer Office within the Internal Revenue Service ("Service"). My responsibilities include the executive management and oversight of one of the offices that administers the regulations governing practice before the Service (reprinted as "Treasury Department Circular No. 230"), including acting on applications to practice before the Service and administering competency testing and continuing education. These aspects of my duties require knowledge and an understanding of the registered tax return preparer program covered by the district court's Order dated January 18, 2013 ("the Order"), as modified on February 1, After being notified of the Order, I directed that all reasonable efforts be undertaken to comply with the terms of the Order. I consulted with other Service executives and employees who are involved in the registered tax return preparer program, as well as with the attorneys in the Department of Justice and the Service's Office of Chief Counsel, about the Order's consequences for the Service. I also consulted with the Service's government contract specialists and attorneys after being notified of the modification to the Order.
2 USCA Case # Document # Filed: 02/25/2013 Page 2 of 11 I conclude that the Service will be irreparably injured absent a stay of the Order pending final resolution of this lawsuit because of the financial harm to the government, as well as the harm to tax administration and the public. The basis for my conclusion is set forth in paragraphs 6-21 of this declaration. FINANCIAL HARM Irreparable financial harm will result from the Service's obligation under the Order to halt the registered tax return preparer program pending final resolution of the appeal. The Service's implementation of the registered tax return preparer program started in Since that time, the Service has invested an enormous amount of time, money, and other resources to establish a registration system, and a minimum competency examination and continuing education program, along with accompanying enforcement measures. If the Order is not stayed, but ultimately overturned on appeal, the Service will incur substantial costs to restart the program. The Service estimates that, absent a stay, the contract costs alone for the next year associated with any such restarting will be, at a minimum, $20 million, not including additional non-contract costs such as labor, travel, outreach, and other related expenses. 7. In 2010, with the assistance of a contractual vendor, the Service replaced its voluntary process for issuing preparer tax identification numbers ("PTIN") with a new mandatory PTIN process. The Service began implementing the new PTIN application process for all tax return preparers, including attorneys, certified public accountants, enrolled agents, and registered tax return preparers. In 2012, over 744,000 tax return preparers registered with the Service. Although 2
3 USCA Case # Document # Filed: 02/25/2013 Page 3 of 11 the Order as modified stated that the PTIN application process falls outside the scope of the Order, the Order will nevertheless require the Service to modify its online PTIN application process and paper forms. The application system and form were designed and implemented in a manner that integrates the mandatory testing and continuing education requirements with the PTIN application and renewal process. For example, continuing education requirements are reported on the PTIN renewal application. Every change to the PTIN application process or system that is not specifically covered by the Service's current contract with its vendor requires a contract modification. Each new requirement can result in a new cost to the Service. The Service will therefore incur additional costs in shutting down the PTIN application system, changing the system requirements through reprogramming, and restarting the system because these actions are not covered by the existing vendor contract. 8. There are similar costs associated with shutting down and reopening call center operations supporting the PTIN application process, as well as costs associated with increasing call volumes over a previously specified number. The Order, moreover, has created confusion in the return preparer community. This confusion has caused an increase in the number of calls to the call center, and the increased call volume will result in additional costs to the Service. The costs and time involved in securing any necessary modifications to existing contracts with vendors for the PTIN application process are expected to be significant. 3
4 USCA Case # Document # Filed: 02/25/2013 Page 4 of 11 Although the specific costs to date are undetermined, as precise vendor costs have yet to be submitted to the Service, the Service is currently negotiating a modification to its existing call center contract to accommodate an additional 150,000 calls. This will likely result in an increased cost to the Service in the range of $ million (and perhaps more, depending on call volume). Although the Service was in the process of renegotiating its call center contract even before the Order was issued, the increase in calls attributable to the Order will increase the costs the Service will incur. The Service began implementing the registered tax return preparer competency examination with the assistance of a contractual vendor in Since November 2011, (i) almost 101,000 tests were scheduled by preparers for the examination, and (ii) more than 62,300 preparers have passed the examination. There are 260 testing centers across the United States and its territories. Up to the date of the Order, ongoing activities in implementing the examination included drafting and reviewing the examination questions, setting up additional test sites, developing a Spanish language version of the test, scheduling and proctoring examinations, running a call center to answer questions, providing communications and customer support, and collecting the user fee to take the competency examination. 11. The Service began developing and implementing the continuing education program in In 2012, the Service approved 642 continuing education providers, who offered 18,000 courses for purposes of the continuing education program. Up to the date of the Order, ongoing activities in 4
5 USCA Case # Document # Filed: 02/25/2013 Page 5 of 11 implementing the continuing education program included approving continuing education providers who are authorized to offer continuing education, modifying the PTIN system to allow providers to upload courses completed by preparers, allowing preparers to check their own accounts for completed courses, and providing a referral process. There are 167 Return Preparer Office employees, including 119 user-fee-funded positions, supporting the return preparer program. These employees also provide preparer assistance, complaint processing, compliance and enforcement oversight, and a multitude of other services in support of tax practitioners. The total monetary cost spent by the Service on the return preparer program through the end of calendar year 2012 was more than $54 million. The total monetary cost spent by the Service on the return preparer program during January 2013 until the date of the Order was approximately $897,000. On average, the Service received each month approximately $3.7 million in PTIN user fees (beginning September 2010) and $190,000 in competency testing user fees (beginning December 2011). The combined PTIN and competency testing user fees received by the Service through the end of calendar year 2012 exceeded $105 million, which sum may only be spent on the registered tax return preparer program in accordance with the government's budget, appropriation, and spending rules. After the modification to the Order, I was advised that the Service's existing contract with the vendor that implements the registered tax return preparer competency examination cannot be modified to offer examinations to 5
6 USCA Case # Document # Filed: 02/25/2013 Page 6 of 11 only those individuals who would be willing to voluntarily take the examination. Voluntary testing thus would require an entirely new contract. Accordingly, the district court's observation (in denying a stay) that the Service was free to continue with its return preparer registration program on a voluntary basis is not correct, as the existing contract does not allow voluntary testing. During the course of this litigation the Service expects to receive thousands of requests for refunds and/or reimbursements by preparers who paid for testing and continuing education that the Order states the Service has no authority to impose. Moreover, during the pendency of the appeal, the Service will have to allocate resources and expend funds to address requests for refunds of user fees for tests scheduled prior to the date of the Order that were to be administered after the date of the Order. There are approximately 12,000 preparers who scheduled and paid the $116 user fee for a competency examination they are no longer required to take under the Order and cannot voluntarily take under the existing vendor contract. The amount of such fees is approximately $1.3 million. HARM TO TAX ADMINISTRATION AND PUBLIC The Service will be irreparably harmed by the adverse impact the Order will have on its ongoing compliance and enforcement efforts regarding the registered tax return preparer program. The 2013 filing season for 2012 individual income tax returns began on January 30, The Service has made considerable efforts, has expended significant resources, and has made substantial progress in explaining to the tax return preparer community the new 6
7 USCA Case # Document # Filed: 02/25/2013 Page 7 of 11 registered tax return preparer program requirements and applicable time frames through published guidance, consistent messaging, and outreach efforts. Many tax return preparers have already made arrangements to take the competency examination, which can include making travel arrangements and taking preparatory classes. Many tax return preparers have also already made arrangements to comply with continuing education requirements. Similarly, continuing education providers have spent considerable resources creating and setting up in-person and on-line courses. The Service, for example, offered a number of free on-line courses that allowed tax return preparers to meet all their continuing education requirements for 2012 through web-based programming. The court's modified Order issued on February 1, 2013, has caused confusion and uncertainty among tax return preparers regarding their responsibilities and obligations. For testing alone, during the past 18 months the Service created 5 videos, and initiated 30 outreach efforts across the country, to address testing and the other requirements. These efforts were undertaken to ensure widespread understanding and engagement of the preparer community. In the absence of a stay, the long term cost to tax administration and the public fisc by a failure to provide some minimal standard of competency for unregulated preparers is unquantifiable. The registered tax return preparer regulatory program at issue in this case was established after a comprehensive review (the Return Preparer Review). The Return Preparer Review solicited substantial input from the tax 7
8 USCA Case # Document # Filed: 02/25/2013 Page 8 of 11 return preparer community. The results of the Return Preparer Review demonstrated the necessity to address the problem of inaccurate returns prepared by tax return preparers. A principal objective of the registered tax return preparer program is to protect the public from the injury caused by incompetent or disreputable tax return preparers. The Service estimates that fraud, abuse, and error relating to the earned income tax credit alone costs the taxpaying public about $13 billion annually, and almost two-thirds of all returns claiming the earned income tax credit are prepared by tax return preparers. Furthermore, since the beginning of fiscal year 2010, over 500 tax return preparers have been criminally prosecuted by the Department of Justice based on referrals made by the Service. 18. Identity theft, which also includes theft by unauthorized tax return preparers, is a major national problem, and it also seriously impacts the Service and tax administration generally. The registered tax return preparer program assists in preventing, combating, and resolving the adverse effects resulting from identify theft perpetrated by unscrupulous individuals who file unauthorized returns for others with stolen information, or information from former clients. The registered tax return preparer program also requires registered tax return preparers to pass a suitability check (including a criminal record check), preventing criminals from legally filing tax returns for others. The regulations permit the Service to discipline a registered tax return preparer who has engaged in fraudulent conduct, including identity theft. Without a stay of the Order, the 8
9 USCA Case # Document # Filed: 02/25/2013 Page 9 of 11 protections afforded by the registered tax return preparer program will be substantially impaired and in some instances lost. Beyond the confusion and harm for tax return preparers and the public for the current filing season created by the Order, the Order will detrimentally affect the 2014 filing season (for 2013 individual income tax returns) that will begin in January 2014, as well as future filing seasons. The current requirements for regulating unregulated paid tax return preparers were expected to be fully implemented for the 2014 filing season, allowing the Service to direct taxpayers to preparers with a minimum level of competency to complete their returns. As indicated above, regulation of unregulated preparers is a significant step in improving overall taxpayer and return preparer compliance by reducing the number of errors in prepared returns, identifying preparers who need additional education and outreach, identifying preparers filing fraudulent returns, and developing processes to identify "ghost preparers" (preparers who do not sign tax returns that they prepare). The Order has effectively precluded the Service from rolling out this program at the beginning of The longer the program is in suspension, the more daunting that task becomes because of the cost, confusion, and loss of engagement among the unregulated preparer community. The 2014 filing season will also be adversely impacted because the Service will not be permitted to take important steps to administratively bar persons it knows are improperly preparing tax returns for others from preparing tax returns during the 2014 filing season, which was one of the principal 9
10 USCA Case # Document # Filed: 02/25/2013 Page 10 of 11 objectives of the registered tax return preparer program. Penalties, which generally must undergo an investigation and audit process before assessment against tax return preparers, do not always accomplish the registered tax return preparer program's primary objective of stopping unscrupulous preparers. In addition, the government does not have the resources to bring an injunction lawsuit against all tax return preparers who have improperly prepared tax returns. In the absence of a stay, individuals who were deterred from preparing tax returns because they did not want to undergo a suitability check, pass an examination, or take relevant continuing education, will be able to prepare tax returns for clients during the 2014 filing season. Once again, there will be no regulatory program to provide competency or ethical standards for those who are paid to assist most Americans with their largest financial transaction of the year, their tax return. 21. Absent a stay of the Order, the competency and education standards for tax return preparers will be significantly delayed even if the regulations are ultimately upheld on appeal. The Service, for example, may be obliged to provide additional transition relief if the requirements are now 10
11 USCA Case # Document # Filed: 02/25/2013 Page 11 of 11 suspended but later upheld on appeal. This will simply add additional delay to the program which is designed to ensure competent tax return preparation for the taxpaying public. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 25th day of February 2013, in Washington, D.C. 2A0e Carol A. Campbell Director, Return Preparer Office Internal Revenue Service Washington, D.C
Labor Law Regulation Part 60 Pursuant to Section 134 of the Workers. Compensation Law as amended by Chapter 6 of the Laws of 2007
DRAFT as of 08/25/08 Labor Law Regulation Part 60 Pursuant to Section 134 of the Workers Compensation Law as amended by Chapter 6 of the Laws of 2007 PART 60 WORKPLACE SAFETY AND LOSS PREVENTION INCENTIVE
More informationCENTURYLINK ELECTRONIC AND ONLINE PAYMENT TERMS AND CONDITIONS
CENTURYLINK ELECTRONIC AND ONLINE PAYMENT TERMS AND CONDITIONS Effective June 1, 2014 The following terms and conditions apply to electronic and online delivery and presentation of your invoices by CenturyLink
More informationOPR Discipline What You Need To Know
OPR Discipline What You Need To Know Learning Objectives Rules Governing Authority to Practice OPR Referral and Complaint Process Common Circular 230 Violations and Considerations Statutory Authority 31
More informationWorkplace Safety and Loss Prevention Incentive Program (Safety, Drug and Alcohol Prevention, and Return to Work Incentive Programs)
Part 60 Workplace Safety and Loss Prevention Incentive Program (Safety, Drug and Alcohol Prevention, and Return to Work Incentive Programs) Part 60 Workplace Safety and Loss Prevention Incentive Program
More informationUser Fees Relating to the Registered Tax Return Preparer Competency Examination
[4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 300 [REG-116284-11] RIN 1545-BK24 User Fees Relating to the Registered Tax Return Preparer Competency Examination and Fingerprinting
More informationDC: AVNET, INC. VOLUNTARY EMPLOYEE SEVERANCE PLAN
DC: 4069808-3 AVNET, INC. VOLUNTARY EMPLOYEE SEVERANCE PLAN Avnet, Inc. Voluntary Employee Severance Plan TABLE OF CONTENTS Introduction... 1 Eligibility... 2 Eligible Employees... 2 Circumstances Resulting
More informationA Preliminary Analysis: Tax Return Preparer/PTIN Regulations Grace Allison, Tax Strategist, Northern Trust
A Preliminary Analysis: Tax Return Preparer/PTIN Regulations Grace Allison, Tax Strategist, Northern Trust A few preliminary observations: 1. Over the past few months, Treasury has acted swiftly to issue
More informationRegulations Governing Practice Before the Internal Revenue Service
[4830-01-p] DEPARTMENT OF THE TREASURY Office of the Secretary 31 CFR Part 10 [REG-138637-07] RIN 1545-BH01 Regulations Governing Practice Before the Internal Revenue Service AGENCY: Office of the Secretary,
More informationComments to Proposed Loan Discharge Applications Docket ID ED-2017-ICCD-0057 (80 Fed. Reg (April 27, 2017)) June 26, 2017
Comments to Proposed Loan Discharge Applications Docket ID ED-2017-ICCD-0057 (80 Fed. Reg. 19364 (April 27, 2017)) June 26, 2017 As organizations that represent low-income student loan borrowers, we thank
More informationLIST OF SUBSTANTIVE CHANGES AND ADDITIONS Route To: Partners PPC's Guide to Dealing with the IRS Managers. Twenty second Edition (June 2014)
LIST OF SUBSTANTIVE CHANGES AND ADDITIONS Route To: Partners PPC's Guide to Dealing with the IRS Managers Staff File Twenty second Edition (June 2014) The following are some of the features of this year
More informationGAO TAX PREPARER REGULATION. IRS Needs a Documented Framework to Achieve Goal of Improving Taxpayer Compliance
GAO United States Government Accountability Office Report to the Subcommittee on Financial Services and General Government, Committee on Appropriations, U.S. Senate March 2011 TAX PREPARER REGULATION IRS
More informationSECTION 5. SMALL CASE PROCEDURE FOR REQUESTING COMPETENT AUTHORITY ASSISTANCE.01 General.02 Small Case Standards.03 Small Case Filing Procedure
Rev. Proc. 2002 52 SECTION 1. PURPOSE OF THE REVENUE PROCEDURE SECTION 2. SCOPE.01 In General.02 Requests for Assistance.03 Authority of the U.S. Competent Authority.04 General Process.05 Failure to Request
More information1102 Longworth House Office Building 1102 Longworth House Office Building Washington, DC Washington, DC 20515
The Honorable Lynn Jenkins Chairwoman Ranking Member Subcommittee on Oversight Subcommittee on Oversight House Committee on Ways and Means House Committee on Ways and Means United States House of Representatives
More informationSEC. 5. SMALL CASE PROCEDURE FOR REQUESTING COMPETENT AUTHORITY ASSISTANCE.01 General.02 Small Case Standards.03 Small Case Filing Procedure
26 CFR 601.201: Rulings and determination letters. Rev. Proc. 96 13 OUTLINE SECTION 1. PURPOSE OF MUTUAL AGREEMENT PROCESS SEC. 2. SCOPE Suspension.02 Requests for Assistance.03 U.S. Competent Authority.04
More informationThe 2011 Amendments to Circular 230: What's Ahead
CAPLIN & DRYSDALE, CHARTERED ONE THOMAS CIRCLE, N.W. SUITE 1100 WASHINGTON, DC 20005 The 2011 Amendments to Circular 230: What's Ahead Matthew C. Hicks On August 2, 2011, the recent amendments to Treasury
More informationImportance of Disclosures and Cooperation During and After Internal Investigations
Companion Material to OOPS Investigations Seminar - Part II Importance of Disclosures and Cooperation During and After Internal Investigations By: David Robbins, David Hammond and Kelly Currie The rules,
More informationA RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CASTLE PINES, COLORADO APPROVING A PURCHASING POLICY
RESOLUTION NO. 11-41 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CASTLE PINES, COLORADO APPROVING A PURCHASING POLICY WHEREAS, pursuant to Sections 31-15-101 and 31-15-201, C.R.S., a municipality has
More informationUser Fees Relating to Enrolled Agents and Enrolled Retirement Plan Agents. ACTION: Notice of proposed rulemaking and notice of public hearing.
[4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 300 [REG-124018-10] RIN 1545-BJ65 User Fees Relating to Enrolled Agents and Enrolled Retirement Plan Agents AGENCY: Internal
More informationU.S. DEPARTMENT OF HOMELAND SECURITY'S URBAN AREAS SECURITY INITIATIVE GRANT PROGRAM REQUIREMENTS FOR PROCUREMENT CONTRACTS
U.S. DEPARTMENT OF HOMELAND SECURITY'S URBAN AREAS SECURITY INITIATIVE GRANT PROGRAM REQUIREMENTS FOR PROCUREMENT CONTRACTS I. DEFINITIONS A. Agreement means the agreement between City and Contractor to
More informationCOLLEGE OF CHARLESTON STUDENT CONSENT, MEDICAL AUTHORIZATION, AND RELEASE AGREEMENT (International Travel) Name of Program:
COLLEGE OF CHARLESTON STUDENT CONSENT, MEDICAL AUTHORIZATION, AND RELEASE AGREEMENT (International Travel) Name of Program: THIS FORM MUST BE SIGNED AND RECEIVED BY THE CENTER FOR INTERNATIONAL EDUCATION
More informationIndiana Benefits Conference
INTERNAL REVENUE SERVICE Employee Plans Indiana Benefits Conference Practicing as an ERPA before the Internal Revenue Service Debi Lohning Senior Employee Plan Specialist, Senior Program Analyst, ERPA
More informationTable of Contents. EA Exam Part
Table of Contents EA Exam Part 3 2017-18 Introduction... 2 Examination Content Outline... 8 Course Content... 11 Practices and Procedures... 12 Practice before the IRS... 12 OPR and Practice before the
More informationCITY OF PASADENA CITY ATTORNEY
Page 1 of 7 MISSION STATEMENT The mission of the City Attorney/City Prosecutor s Department is to represent the City of Pasadena with the utmost professionalism and to provide the highest quality legal
More informationAdditional Information on the Dirty Dozen
Additional Information on the Dirty Dozen 1. Identity Theft Topping this year s list Dirty Dozen list is identity theft. In response to growing identity theft concerns, the IRS has embarked on a comprehensive
More informationAmerican Bar Association Commission on Ethics 20/20 Resolution
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 The views expressed herein have not been approved by the House of Delegates or the Board of Governors of
More informationIRS Criminal Investigation SPECIAL AGENT FELICIA MCCAIN PUBLIC INFORMATION OFFICER (619)
IRS Criminal Investigation SPECIAL AGENT FELICIA MCCAIN PUBLIC INFORMATION OFFICER (619) 770-9317 FELICIA.MCCAIN@CI.IRS.GOV Areas of Emphasis for CI Abusive Return Preparers International Fraud Refund
More informationExtension of Time to File Certain Information Returns. SUMMARY: This document contains final and temporary regulations
This document is scheduled to be published in the Federal Register on 08/13/2015 and available online at http://federalregister.gov/a/2015-19932, and on FDsys.gov [4830-01-p] DEPARTMENT OF THE TREASURY
More informationNOTICE , I.R.B. 315 (1/17/2011)
Source: IRS Documents > Notices > 2011 > NOTICE 2011-6, 2011-3 I.R.B. 315 (1/17/2011) NOTICE 2011-6, 2011-3 I.R.B. 315 (1/17/2011) Part III Administrative, Procedural, and Miscellaneous Implementation
More informationRULES OF TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE DIVISION OF CONSUMER AFFAIRS RULES AND REGULATIONS FOR DEBT MANAGEMENT SERVICES
RULES OF TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE DIVISION OF CONSUMER AFFAIRS 0780-05-18 RULES AND REGULATIONS FOR DEBT TABLE OF CONTENTS 0780-05-18-.01 Purpose of Rules 0780-05-18-.10 Submission
More informationChapter 14 PROGRAM INTEGRITY
INTRODUCTION Chapter 14 PROGRAM INTEGRITY The PHA is committed to ensuring that subsidy funds made available to BHA are spent in accordance with HUD requirements. This chapter covers HUD and BHA policies
More informationCity of. Carmelita Flagpole, circa 1927
Title pages 2019 print.qnd:layout 1 8/7/18 2:13 PM Page 8 City of Carmelita Flagpole, circa 1927 City AttoRNEy/City PRoSECUtoR CITY ATTORNEY/CITY PROSECUTOR City Attorney / City Prosecutor (1.00) Legal
More informationSelf-Disclosure: Why, When, Where and How
American Bar Association Washington Health Law Summit Self-Disclosure: Why, When, Where and How December 8, 2015 Margaret Hutchinson U.S. Attorney s Office for the Eastern District of Pennsylvania Kaitlyn
More informationMy Rewards Terms and Conditions for Consumer and Commercial Cards
My Rewards Terms and Conditions for Consumer and Commercial Cards My Rewards ( Program ) is a loyalty program available to the holder of a credit, debit and/or prepaid Card ( you or the Cardholder ) issued
More informationInstructions for Completing the ID Theft Affidavit
Instructions for Completing the ID Theft Affidavit To make certain that you do not become responsible for the debts incurred by the identity thief, you must provide proof that you didn t create the debt
More informationUNITED STATES OF AMERICA BEFORE THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C.
UNITED STATES OF AMERICA BEFORE THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C. In the Matter of: COMMUNITY TRUST BANK, INC. Pikeville, Kentucky A State Member Bank Docket No. 18-024-B-SM
More informationChapter 14 PROGRAM INTEGRITY
INTRODUCTION Chapter 14 PROGRAM INTEGRITY The PHA is committed to ensuring that subsidy funds made available to the PHA are spent in accordance with HUD requirements. This chapter covers HUD and PHA policies
More informationChapter 14 PROGRAM INTEGRITY
INTRODUCTION Chapter 14 PROGRAM INTEGRITY The HABC is committed to ensuring that subsidy funds made available to the HABC are spent in accordance with HUD requirements. This chapter covers HUD and HABC
More informationConsumer Federation of America Best Practices for Identity Theft Services. March 10, 2011
Consumer Federation of America Best Practices for Identity Theft Services March 10, 2011 Consumer Federation of America Best Practices for Identity Theft Services Table of Contents Introduction 3 About
More informationTax Identity Shield What to Expect. Tax Identity Shield Terms & Conditions
Tax Identity Shield What to Expect Congratulations! Enrolling in Tax Identity Shield (by signing below) is an important first step in helping to better protect your taxpayer identity. What happens next?
More informationCovered California 3/5/2019. Title 10. Investment. Chapter 12. California Health Benefit Exchange. Article 11. Certified Application Counselor Program
Title 10. Investment Chapter 12. California Health Benefit Exchange Article 11. Certified Application Counselor Program 6850. Definitions. (a) For purposes of this Article, the following terms shall have
More informationTMA Version - April 2005
TITLE 32 NATIONAL DEFENSE CIVILIAN HEALTH AND MEDICAL PROGRAM OF THE UNIFORMED SERVICES (CHAMPUS) PART 199.12 - THIRD PARTY RECOVERIES (a) General. This section deals with the right of the United States
More informationCHAPTER 3B Ethics and Circular 230
CHAPTER 3B Ethics and Circular 230 Disclaimer The contents of this communication are not intended to be nor should it be treated as tax, legal, or accounting advice. Additional issues could exist that
More informationWhat s Next for the Department s Borrower Defense Rule?
What s Next for the Department s Borrower Defense Rule? AARON LACEY PARTNER, HIGHER EDUCATION PRACTICE THOMPSON COBURN LLP Aaron D. Lacey o Partner, Higher Education Practice, Thompson Coburn LLP. Higher
More informationInsurance Coverage Law
Ohio State Bar Association Insurance Coverage Law Attorney Information and Standards Accredited by the Supreme Court Commission on Certification of Attorneys as Specialists Contents Insurance Coverage
More informationImportant Disclosure Information Massachusetts Addendum
Quality health plans & benefits Healthier living Financial well-being Intelligent solutions a Important Disclosure Information Massachusetts Addendum Massachusetts Mental Health Parity Laws and the Federal
More informationPLF Claims Made Excess Plan
2019 PLF Claims Made Excess Plan TABLE OF CONTENTS INTRODUCTION... 1 SECTION I COVERAGE AGREEMENT... 1 A. Indemnity...1 B. Defense...1 C. Exhaustion of Limit...2 D. Coverage Territory...2 E. Basic Terms
More informationThe National Association of Community Health Centers, Inc. Issue Brief on. Complying with the FTC s Red Flag Rules. February, 2009
1/28/2009 The National Association of Community Health Centers, Inc. Issue Brief on Complying with the FTC s Red Flag Rules February, 2009 Prepared for NACHC by: Michael Glomb Feldesman Tucker Leifer Fidell,
More informationRevenue Procedure 97-27
CLICK HERE to return to the home page Revenue Procedure 97-27 TABLE OF CONTENTS SECTION 1. PURPOSE.01 In general.02 Voluntary compliance.03 Significant changes SECTION 2. BACKGROUND.01 Change in method
More informationA. Circular 230 Proposed Regulations - September 2010
OUTLINE LEGAL ISSUES RELATED TO PAID PREPARER REQUIREMENTS FORMS 8038 By Nancy M. Lashnits Phoenix, Arizona A. Circular 230 Proposed Regulations - September 2010 1. The IRS published another round of Circular
More informationBUSINESS DEBIT CARD AGREEMENT
BUSINESS DEBIT CARD AGREEMENT BUSINESS DEBIT CARD AGREEMENT 1. Agreement... 1 2. Business Account... 1 3. Business Purpose... 1 4. Fees... 1 5. Cardholders... 1 6. Card Transactions (a) Point of Sale Transactions...
More informationMassMutual AAP February 2013 Page 1 of 21
MassMutual Agents Assistance Program Summary Plan Description for Career Agents, General Agents and General Managers of MassMutual Effective January 1, 2013 This Summary Plan Description (SPD), published
More informationFEDERAL EMERGENCY MANAGEMENT AGENCY S GRANT PROGRAM REQUIREMENTS FOR PROCUREMENT CONTRACTS
FEDERAL EMERGENCY MANAGEMENT AGENCY S GRANT PROGRAM REQUIREMENTS FOR PROCUREMENT CONTRACTS I. DEFINITIONS A. Agreement means the agreement between City and Contractor to which this document (Federal Emergency
More informationIntroduction: Section 2: Management of Purchase Cards
Introduction: The Office of Charge Card Management (OCCM) has developed a point by point analysis of S.300, otherwise known as the Charge Card Abuse Prevention Act, in order to illustrate the overlap between
More informationH e a l t h C a r e Compliance Adviser
March 2001 Volume 5 Number 1 H e a l t h C a r e Compliance Adviser OIG Issues New Advisory Opinion on Gainsharing Reversing July 1999 Special Advisory Bulletin In a welcome departure from its former position,
More informationCOLLEGE OF CHARLESTON LIABILITY RELEASE, EMERGENCY MEDICAL AUTHORIZATION AND AGREEMENT (Domestic Travel)
COLLEGE OF CHARLESTON LIABILITY RELEASE, EMERGENCY MEDICAL AUTHORIZATION AND AGREEMENT (Domestic Travel) 1. I, the undersigned student desire to participate in the following activity/trip ( Activity ),
More informationJennifer Putt, CFE Manager of Program Integrity August 12, VBH-PA Provider Self-Audit Protocol
VBH-PA Provider Self-Audit Protocol Jennifer Putt, CFE Manager of Program Integrity August 12, 2016 1 Topics for Today s Presentation Background and Requirements for Provider Self- Audits Examples of Inappropriate
More informationOffer-in-Compromise Why or Why Not
Why or Why Not The Capital of Texas Enrolled Agents November 2010 by: lg brooks, ea Why or Why Not Table of Contents Introduction 3 The Offer Process 4 The Offer in Compromise: Offers in General 4 Grounds
More information(4) Before afederal court. 14
26 CFR 601.204: Changes in accounting periods and in methods of accounting. (Also Part I, 446, 481; 1.446 1, 1.481 1, 1.481 4.) Rev. Proc. 97 27 TABLE OF CONTENTS PAGE SECTION 1. PURPOSE... 11.01 In general...
More informationMEMORY BANK ACCOUNT RULES (continued)
MEMORY BANK ACCOUNT RULES These Account Rules apply to any deposit account provided by Memory Bank, a division of Republic Bank & Trust Company, (hereafter referred to as Bank, we, us, or our ). Throughout
More informationdentons.com Telephone Consumer Protection Act (TCPA)
Telephone Consumer Protection Act (TCPA) Telephone Consumer Protection Act (TCPA) Overview Many businesses today still attract customers the oldfashioned way: by calling them. Customer solicitation/ retention
More informationFORGIVE AND FORGET - - THE CALIFORNIA EMPLOYMENT TAX AMNESTY. By Steven Toscher, Esq. March, 1995
FORGIVE AND FORGET - - THE CALIFORNIA EMPLOYMENT TAX AMNESTY By Steven Toscher, Esq. March, 1995 INTRODUCTION Should a taxing authority be able to forgive and forget - - that is, grant amnesty to taxpayers
More informationSUMMARY: This document contains temporary regulations relating to the imposition of
This document is scheduled to be published in the Federal Register on 10/30/2015 and available online at http://federalregister.gov/a/2015-27789, and on FDsys.gov [4830-01-p] DEPARTMENT OF THE TREASURY
More information2018 LEGISLATIVE AND REGULATORY POLICIES
2018 LEGISLATIVE AND REGULATORY POLICIES The Florida Institute of CPAs is committed to the advancement of Florida s CPA profession. As such, the Institute believes a vital part of its service role to the
More informationOnline and Electronic Banking Services Agreement
Online and Electronic Banking Services Agreement January 14, 2015 In this Agreement, the words "you" or "your" mean the member or business that has enrolled in Evergreen Credit Union's Online and Electronic
More informationDESERT COMMUNITY COLLEGE DISTRICT General Terms and Conditions
DESERT COMMUNITY COLLEGE DISTRICT www.collegeofthedesert.edu General Terms and Conditions 1. PURCHASE ORDER DEFINED: The term purchase order as used in these terms conditions means the document entitled
More informationNOTICE OF PRIVACY PRACTICES SOUTH DAYTON ACUTE CARE CONSULTANTS, INC.
NOTICE OF PRIVACY PRACTICES SOUTH DAYTON ACUTE CARE CONSULTANTS, INC. THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE
More informationAMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS
AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS Comments on Proposed Regulations, REG-138637-07 Relating to Regulations Governing Practice Before the Internal Revenue Service October 7, 2010 In REG-138637-07
More informationEthics and Professional Responsibility for Enrolled Agents
Ethics and Professional Responsibility for Enrolled Agents #4525M COURSE MATERIAL TABLE OF CONTENTS Chapter 1: IRS Circular 230 1 Chapter 1: Test Your Knowledge 33 Chapter 1: Solutions and Suggested Responses
More informationCase 3:12-cv HZ Document 23-1 Filed 11/25/13 Page 1 of 15 Page ID#: 87
Case 3:12-cv-02006-HZ Document 23-1 Filed 11/25/13 Page 1 of 15 Page ID#: 87 STUART F. DELERY Assistant Attorney General MAAME EWUSI-MENSAH FRIMPONG Deputy Assistant Attorney General MICHAEL S. BLUME Director,
More informationCity of Albany/Water, Gas & Light. Your Group Short Term Disability Plan
City of Albany/Water, Gas & Light Your Group Short Term Disability Plan Policy No. 152208 011 Underwritten by Unum Life Insurance Company of America 2/3/2009 CERTIFICATE OF COVERAGE Unum Life Insurance
More informationCorporate Legal Policy
Corporate Legal Title Number Current Effective Date Original Effective Date Replaces Cross Reference Fraud, Waste and Abuse General Information & Reporting CP.LE.SI.001.v1.5 04/20/18 03/19/04 External
More informationCommon Stock Par Value $.01 per Share Dividend Reinvestment and Stock Purchase Plan
Common Stock Par Value $.01 per Share Dividend Reinvestment and Stock Purchase Plan This prospectus describes Bank of Hawaii Corporation s Dividend Reinvestment and Stock Purchase Plan ( the Plan ). The
More informationLife Insurance Council Bylaws
Life Insurance Council Bylaws Effective January 1, 2007 Amended 05/2008 Bylaw 10, Section 2; Schedule A, Part II, Section 4 Amended 05/2009 Bylaw 5, Section 1, Section 5; Bylaw 7, Section 5 Amended 10/2009
More informationNFA response to government consultation on social housing fraud
NFA response to government consultation on social housing fraud March 2012 Introduction The National Federation of ALMOs (NFA) represents 55 ALMOs which manage over 800,000 council homes across 54 local
More informationUniform Rules of Practice Circuit Court of Illinois Nineteenth Judicial Circuit
If a l ~ DEC 1 4 2015 Uniform Rules of Practice Circuit Court of Illinois Nineteenth Judicial Circuit ~~ CIRCUIT CLERK Amendment to Rule 19.00, LAKE COUNTY RESIDENTIAL REAL ESTATE MORTGAGE FORECLOSURE
More informationPart Overpayments Recovery
Title 32 National Defense Revision: Rule: (a) General. Actions to recover overpayments arise when the government has a right to recover money, funds or property from any person, partnership, association,
More informationWorking Together. Pennsylvania Department of Revenue Updates and Information
Working Together Pennsylvania Department of Revenue Updates and Information 1 Pennsylvania Voluntary Disclosure Program Liaison Officers Alicia Danner & Matthew Pettigrew Purpose/Availability/History The
More informationEXHIBIT 7 1 Flow Chart for Chapter 12
EXHIBIT 7 1 Flow Chart for Chapter 12 The Filing of the Chapter 12 Petition The debtor files with the bankruptcy court clerk s office: 1. Filing fee and administrative fee 2. Voluntary petition (Official
More informationHEALTH INSURANCE UTILIZATION REVIEW, APPEALS AND GRIEVANCES AND EXTERNAL REVIEW
A CONSUMER S GUIDE TO HEALTH INSURANCE UTILIZATION REVIEW, APPEALS AND GRIEVANCES AND EXTERNAL REVIEW If you are a health care consumer and have a complaint about your insurer s denial of a claim or some
More informationGoals for Today s Presentation
AMERICAN HEALTH LAWYERS ASSOCIATION Institute on Medicare and Medicaid Payment Issues March 26-28, 2014 Baltimore, Maryland Medicare and Medicaid Overpayments and Refunds Presented by: Robert L. Roth,
More informationLEGAL DEFENSE FUND. Program Document and Summary Program Description CCPOA. Benefit Trust Fund
LEGAL DEFENSE FUND Program Document and Summary Program Description CCPOA Benefit Trust Fund CCPOA LEGAL DEFENSE FUND and certain other Legal Service Benefits PLAN DOCUMENT AND SUMMARY PLAN DESCRIPTION
More informationFEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C.
FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. ) ) In the Matter of ) ) CONSENT ORDER, ORDER WEX BANK ) FOR RESTITUTION, AND MIDVALE, UTAH ) ORDER TO PAY ) CIVIL MONEY PENALTY ) ) FDIC-15-0117b
More informationFERRIS STATE UNIVERSITY HEALTH PLAN SUPPLEMENTAL INFORMATION. Bargaining Unit Employees
FERRIS STATE UNIVERSITY HEALTH PLAN SUPPLEMENTAL INFORMATION Bargaining Unit Employees AFSCME Public Safety Officers Public Safety Supervisors Nurses Effective July 1, 2005 1247959-2 TABLE OF CONTENTS
More informationAdvertisement of Life Insurance and Annuities; Disclosure Requirements for
INSURANCE 44 NJR 6(1) June 4, 2012 Filed May 9, 2012 DEPARTMENT OF BANKING AND INSURANCE OFFICE OF LIFE AND HEALTH Advertisement of Life Insurance and Annuities; Disclosure Requirements for Annuities Directly
More information(Senate Bill 734) Courts and Judicial Proceedings Structured Settlements Transfers and Registration of Structured Settlement Transferees
Chapter 722 (Senate Bill 734) AN ACT concerning Courts and Judicial Proceedings Structured Settlements Transfers and Registration of Structured Settlement Transferees FOR the purpose of making certain
More informationExpress Credit Line Agreement & Disclosure
Interest Rate and Interest Charges Express Credit Line Agreement & Disclosure Annual Percentage Rate (APR) for Cash Advances 14.900% Paying Interest You will be charged interest starting on the transaction
More information100TH GENERAL ASSEMBLY State of Illinois 2017 and 2018 HB0690
*LRB00000KTG00b* 0TH GENERAL ASSEMBLY State of Illinois 0 and 0 HB00 by Rep. Carol Ammons SYNOPSIS AS See Index INTRODUCED: Amends the Day and Temporary Labor Services Act. Requires a day and temporary
More informationBall & Gillespie Polygraph
Ball & Gillespie Polygraph 190 West Dayton, Suite 103, Edmonds, WA 980201 (425) 775-9015 INDEMNIFICATION AGREEMENT THIS AGREEMENT is made by and between Ball & Gillespie Polygraph, a division of TMB Enterprises
More informationEmployee Relations. Recent Legislative Changes Require Immediate Employer Action and Point to Future Trends. Anne E. Moran
VOL. 35, NO. 1 SUMMER 2009 Employee Relations L A W J O U R N A L Employee Benefits Recent Legislative Changes Require Immediate Employer Action and Point to Future Trends Anne E. Moran This column discusses
More informationUNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 79795 / January 13, 2017 ADMINISTRATIVE PROCEEDING File No. 3-17774 In the Matter of SOCIEDAD
More informationUniversity of Maine System. Full-time Represented and Non-Represented Faculty. Short Term Disability Coverage
University of Maine System Full-time Represented and Non-Represented Faculty Short Term Disability Coverage Benefit Highlights SHORT TERM DISABILITY PLAN This short term disability plan provides financial
More informationStatement for the Record. Hearing on the Social Security Disability Fraud Scheme in New York
Statement for the Record Hearing on the Social Security Disability Fraud Scheme in New York Subcommittee on Social Security House Committee on Ways and Means January 16, 2014 Submitted on behalf of the
More informationThe IG s Role in Promoting Ethics in Government John A. Carey INSPECTOR GENERAL
ENHANCING PUBLIC TRUST IN GOVERNMENT The IG s Role in Promoting Ethics in Government John A. Carey INSPECTOR GENERAL History of U.S. Inspectors General. The Palm Beach County Office of Inspector General.
More informationNotice of Class Action and Proposed Settlement. You may be entitled to receive benefits under this class action settlement.
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Notice of Class Action and Proposed Settlement You may be entitled to receive benefits under this class action settlement. This notice
More informationReasonable Compliance Needed
Reasonable Compliance Needed Florida ARF and its members encourage the Florida Legislature to pursue revisions in law and practice that support reasonable compliance with Medicaid law rather than a punitive
More informationIMPROVING SMALL BUSINESSES ACCESS TO CAPITAL THROUGH REGULATION OF SBA LOAN BROKERS ACT OF 2016 H.R. A BILL
IMPROVING SMALL BUSINESSES ACCESS TO CAPITAL THROUGH REGULATION OF SBA LOAN BROKERS ACT OF 2016 H.R. A BILL For the establishment, licensing, and oversight of SBA Loan Brokers Be it enacted by the Senate
More informationUNITED STATES OF AMERICA CONSUMER FINANCIAL PROTECTION BUREAU. The Consumer Financial Protection Bureau (Bureau) has reviewed the practices
2016-CFPB-0009 Document 1 Filed 04/25/2016 Page 1 of 29 UNITED STATES OF AMERICA CONSUMER FINANCIAL PROTECTION BUREAU ADMINISTRATIVE PROCEEDING File No. 2016-CFPB- 0009 In the Matter of: CONSENT ORDER
More informationNew York City Department of Consumer Affairs. Notice of Public Hearing and Opportunity to Comment on Proposed Rules
New York City Department of Consumer Affairs Notice of Public Hearing and Opportunity to Comment on Proposed Rules What are we proposing? The Department of Consumer Affairs is proposing to improve and
More information200 Park Avenue New York, New York Telephone: (212) Facsimile: (212)
GIBSON, DUNN & CRUTCHER LLP Janet M. Weiss (JW-5460) 200 Park Avenue New York, New York 10166-0193 Telephone (212) 351-4000 Facsimile (212) 351-4035 Hearing Date August 20, 2007 at 230 PM Objection Deadline
More informationINTERNAL MANUAL -- PASSPORT CERTIFICATION PROCEDURES
INTERNAL MANUAL -- PASSPORT CERTIFICATION PROCEDURES (Excerpted from IRS Internal Manual. https://www.irs.gov/irm. Both sections below are substantially the same. The first applies to field collection
More information