Guest Grumpy456 Posted December 31, 2008 Posted December 31, 2008 In Section 15.05 of Revenue Procedure 2005-16, the IRS permits VS practitioners, in certain circumstances, to amend a client's document on the client's behalf. In Announcement 2005-37, the IRS laid out a pretty clear procedure that VS practitioners must follow in order to do so. Does anyone know whether the IRS has updated or changed the procedure it laid out in Announcement 2005-37? I've heard of a number of VS practitioners who have amended their client's documents on their client's behalf in ways which ignore or only partially satisfy the procedure described in Announcement 2005-37 based, apparently, on "informal" guidance from the IRS that they (the IRS) wouldn't enforce the procedures in Announcement 2005-37 for certain amendments, e.g., 415 final regs and definition of NRA. Has anyone else heard that? If so, where and from who?
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