A research project related to research of the Professional of Conduct of:

-American Institute of CPA's (AICPA)
-Statement of Standards for Tax Services (SSTS) (effective January 2010)
-United States Department of Treasury / IRS Circular 230 (effective June 2014) - I provide a summary in slide form but you should access the full text before answering.
-California Board of Accountancy, Code of Conduct (under California Code of Regulations, Title 16) and the
-PCAOB rules of Professional Conduct, as a result of Sarbanes Oxley Act

Scenario 1
PricewaterhouseCoopers (PwC) announced on October 28 a strategic business alliance ("joint business arrangement") with Google to deliver "new and innovative business solutions to companies around the world, leveraging PwC's unique business insights and using Google tools" (roughly paraphrased). They further announced that they themselves had implemented various new business applications in their own professional service activities and had trained their professionals in the use of the new tools. Access the announcement on the internet -
- Given the discussions we have had and the codes of professional conduct we have reviewed, what issues might arise in this type strategic business arrangement and what could be the potential adverse outcomes to PwC ? When you mention a potential adverse outcomes, be specific as to the cause and potential impact. Which of the potential adverse outcomes for PwC might be the less understood by the investing public?

Scenario 2
If you are providing tax services to a client, can you:
- Sign / submit a tax return that contains a tax position that is supportable by the available client provided information and has a realistic possibility of success? If so, what does that mean and what disclosures should be made in the tax return that is filed? If disclosure is required in the tax return that is filed, and the client refuses to provide that disclosure, what do you need to do?
- Submit / file a tax return that contains a tax position that is more likely than not to be accepted by the tax authorities? If so, what does that mean and is any disclosure in the tax return required?
- Should the tax professional allow him/herself to be engaged to do tax work when the sole purpose of the client engaging you is to avoid tax? If so, what should the tax professional do before accepting such an engagement, if anything?
- If the work described above was accepted, would that tax professional be required to be registered to be allowed to represent the client's case before the Federal tax authority and in what circumstances? Can anyone represent taxpayers with the Federal Tax authorities? What if anything is required?