Tax Advice Research Articles

REQUERIMIENTOS EN ASESORÍA CONTABLE Y TRIBUTARIA EN LAS PYMES DE MANTA, ECUADOR

El proyecto para evaluar la necesidad de una empresa que realice asesoría contable y tributaria en la ciudad de Manta, se lleva a cabo con la finalidad de contribuir al desarrollo sectorial de las Pymes que operan en este cantón; el estudio se enfoca directamente en analizar las necesidades latentes de la mayoría de empresas de esta categoría en temas contables y tributarios, para de esta manera analizar la situación de las pymes que requieren los servicios de asesoría contable y tributaria, mediante un análisis de mercado según las cinco fuerzas de Porter. La investigación se llevó a cabo mediante la metodología bibliográfica documental y de campo, utilizando herramientas como la entrevista y la encuesta, orientadas a los gerentes de las firmas de consultoría contable ya existentes y a las Pymes de la ciudad de Manta respectivamente. Los resultados arrojados por la investigación realizada concluyen en la necesidad del proyecto de creación de una empresa asesora contable y tributaria que oferte sus servicios a las pymes de la ciudad de Manta, contando con alta aceptación dentro de este sector. Palabras clave: contabilidad, tributación, empresa, pymes, fuerzas de Porter.

Legislated Interpretation and Tax Avoidance in Canadian Income Tax Law

Predictable statutory interpretation helps ensure the reliable operation of contemporary systems of taxation. Tax liabilities that are not clearly expressed and articulated by legislatures lead to over-reliance on litigation as a means to enforce and clarify legislative intent. For this reason, modern legislatures continually amend and draft new tax provisions, reformulating existing rules and introducing new ones to address ever-changing social and economic environments. Moreover, legislatures also respond with amendments directed at judicial decisions with which they disagree, as well as the transactions and arrangements at issue in these cases. As these amended and new rules are then subject to application and interpretation by revenue departments, taxpayers, tax advisors, and the courts, all of which legislatures may respond to through further subsequent amendments, tax legislation at any given time can be regarded as the recursive product of an ongoing dialogue. At the same time, the proliferation of ever-more detailed provisions in tax legislation greatly increases the complexity of these statutes. The consequent tendency toward textual interpretation of tax legislation can facilitate tax avoidance that undermines the capacity of a tax system to raise revenue in a manner that is fair or equitable. For this reason, tax statutes like the Canadian Income Tax Act (ITA) typically combine detailed statutory provisions with more broadly-worded anti-avoidance rules that deny unintended tax advantages that might otherwise result from other statutory provisions. At the apex of these anti-avoidance rules stand general anti-avoidance rules (GAARs) like section 245 of the ITA. Section 245 denies tax benefits resulting from tax-motivated transactions that result in a misuse of other provisions of the ITA or other relevant enactments, or an abuse having regard to these provisions read as a whole. In order to “legislate” statutory interpretation, therefore, legislatures generally employ two different approaches: enacting detailed rules in response to changing circumstances and judicial decisions, while simultaneously directing courts to prevent abusive tax avoidance by applying more generalized standards that require them to go beyond or behind the text of the tax legislation in order to deny tax benefits claimed by taxpayers that conflict with the object, spirit or purpose of these provisions. As this paper explains, judicial experience in Canada demonstrates a tension between these two approaches, since the existence of detailed statutory rules can make courts reluctant to apply a general anti-avoidance rule that requires them to depart from the statutory text. This paper considers the GAAR in section 245 of the ITA as an example of legislated statutory interpretation, explaining the origins and structure of this provision and the extent to which it has shaped the interpretation of Canadian income tax law. Part II provides a background to the GAAR, contrasting the textual and formalist approach to tax statutes that was traditionally adopted by English and Canadian courts with the more purposive and substantive approach adopted by U.S. courts as well as English and Canadian courts in the 1980s and early 1990s. Part III explains the basic structure of the GAAR and the way in which Canadian courts have interpreted key elements of this provision. Part IV reviews key tax avoidance cases after the GAAR was introduced, illustrating a lingering affect of pre-GAAR interpretive approaches in the post-GAAR world, from which the courts have only begun to depart. Part V concludes.

Accessible Reliable Tax Advice

Unsophisticated taxpayers who lack financial resources are disadvantaged by a shortage of adequate tax advice. The IRS does not have the resources to answer all questions asked, and the IRS’s informal advice comes with no guarantee as to its accuracy and offers the taxpayer no protection when it is mistaken. Furthermore, non-IRS sources of advice have not sufficiently filled the void left by a lack of satisfactory IRS guidance. These biases against unsophisticated taxpayers have been noted by existing literature. This Article contributes to existing literature by proposing several novel reform measures to assist unsophisticated taxpayers. First, with respect to certain key provisions intended to benefit low-income taxpayers, such as the earned income tax credit, Congress should act to provide unsophisticated taxpayers the protection offered by more formal types of guidance. In order to implement this first proposal, Congress should direct the IRS to verify and stand behind the accuracy of tax software that addressed key provisions, such as the earned income tax credit. The government would stand behind its guarantee of accuracy in two respects. First, if a taxpayer provided accurate information when operating the software and the software indicated, wrongly, that the taxpayer was entitled to certain tax benefits, the IRS would not later assess additional tax liability, interest, or penalties against the taxpayer. Second, if a taxpayer provided accurate information when operating the software, the software indicated, wrongly, that the taxpayer was not entitled to certain tax benefits, and the taxpayer discovered this error after the typical limitations period for filing an amended return had expired, then Congress would grant the taxpayer additional time to amend his or her tax return to claim the benefits to which he or she was, in fact, entitled. Second, this Article proposes that states should require that certified public accountants either provide a minimum number of hours of pro bono services annually or donate a minimum amount annually to support Volunteer Income Tax Assistance sites. Third, Congress should implement a new procedure for assessing penalties and interest against taxpayers whose incomes are below a certain threshold. Under this new procedure, if the taxpayer’s return was prepared by a paid preparer, any penalties and interest that would otherwise be assessed against the taxpayer should be assessed, instead, against the preparer, unless the preparer could prove either that he or she sought adequate information from the taxpayer and tax consequences were reported correctly based on the information provided by the taxpayer or that the taxpayer knowingly waived the right to have penalties and interest assessed against the preparer. In addition, if a preparer did obtain a waiver, the preparer would be precluded from offering any type of audit insurance (or, stated another way, if the preparer did offer any type of audit insurance, doing so would nullify the waiver).

Konstytucyjne źródła funkcjonowania samorządu zawodowego doradców podatkowych w Polsce

The article focuses on the characteristics of the constitutional grounds for functioning of the professional self-government association of tax advisors in Poland. The initial part of the article includes presentation of the definition of self-government, professional self-government association, and the problem of the so-called constitutionality of self-government of professions of public trust, including tax advisors. A very important element is presentation of the duty of professional self-government associations of tax advisors to exercise supervision over proper performance of the profession. The objective of the article, on the background of the deliberations, is to answer the question of whether it is possible to eliminate this professional self-government association – the answer I provided in the conclusions is negative.

State Aid and Taxation of Transnational Companies: A Study of State-Corporate Crime

This study examines the taxation of transnational companies from the perspective of state-corporate crime. As in Sutherland’s pioneering study on white-collar crime, the author relies, in this case, on administrative decisions issued by the European Commissioner for Competition regarding Fiat and Starbucks. According to the Commissioner, the tax advisors of these organizations prepared and submitted special tax rulings on behalf of their clients that were granted by the Luxembourg and Dutch tax authorities, respectively. However, these tax rulings were considered illegal under European law, as they constitute state aid. Therefore, the Commissioner fined Fiat and Starbucks. In this inquiry, state aid from tax rulings is conceived as a process of capital accumulation that arises from states’ regimes of permission based on the interactions between public sector and private sector actors. Thus, an observable symbiosis between tax authorities and transnational companies allowed the latter to use tax regulations in a manipulative way, while the former exercised weak/undue control. This study also unveiled the criminogenic role of tax advisors, an industry that is rarely held accountable for their actions.

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How far have the Manx courts been affected by the Futter and Pitt cases?

This Isle of Man High Court has considered a claim to set aside a flawed trustee decision on the basis of the rule in Hastings-Bass and mistake. Setting it aside, it went on to express doubt as to whether Manx courts might adopt the suggestion of the Supreme Court in Pitt and Futter that relief might be denied in the case of faulty tax advice or honest tax planning.

MENELISIK PERBEDAAN PEMBETULAN SPT DENGAN PENGUNGKAPAN KETIDAKBENARAN SPT

Tax societies should understand well about taxregulations. Moreover a tax authority is expected to be able to provide tax advice to taxpayers well, oversee compliance of tax obligations, and analyze and propose control measures. An understanding of technical knowledge of taxation especially The General Provisions And Tax Procedures Law is extremely needed by both taxpayers and the staff of The Directorate General of Taxation. By understanding the regulation properly, a tax authority can provide guidance or an advise to the taxpayers in order to secure tax revenues.Thus,besides following“rulesof the game” in taxation, a taxpayers can also give contribution in financing national life.

Antecedents of taxpayers’ intentions to engage in tax evasion: evidence from Barbados

PurposeTax evasion has been a major problem for governments around the world, with innovative and ever-changing schemes making the practice increasingly difficult to regulate. In light of this, this study aims to use the extended version of the theory of planned behaviour (TPB) (Beck and Ajzen, 1991) to predict individuals’ intentions to engage in tax evasion.Design/methodology/approachThe research adopts a two-stage approach for data collection and analysis. First, the authors obtained survey data from 150 taxpayers in Barbados to conduct multivariate analyses to test the validity of the study’s hypotheses. The authors also used several open-ended questions on the survey instrument to conduct thematic analyses to further explore the influence of the antecedents of intentions to engage in tax evasion. Second, the authors conducted a focus group with two tax officials and three tax advisors.FindingsThe authors find that attitudes toward the behaviour, perceived behavioural control and moral obligation are significant predictors of intentions to engage in tax evasion. Factors cited as encouraging tax evasion are perceived fairness, tax authorities’ institutional infrastructure and responses, potential financial benefit, perceptions of inequality, low level of trust in tax authorities, perceived poor use of tax revenues and poor treatment of taxpayers. Conversely, factors cited as discouraging tax evasion include fear of prosecution, high morals and potential adequate governmental regulation.Research limitations/implicationsThe study measures intentions to engage in tax evasion rather than actual behaviour. The study does not measure social desirability bias.Originality/valueThis paper tests the applicability of variables used in the extended version of the TPB to predict intentions to engage in tax evasion in a Caribbean-based emerging economy. It also applies a mixed-methods approach of collecting data from taxpayers, tax advisors and tax officials.

Retention of data in the new Anti-money Laundering Directive—‘need to know’ versus ‘nice to know’

The fourth Anti-Money Laundering (AML) Directive1 was adopted in June 2015, and in July 2016, a little more than one year after the adoption, the procedures for amending it again were initiated.2 As stated in Article 1(1), the AML Directive aims to prevent the use of the financial system in the Member States for the purposes of two well defined and relatively new crimes, money laundering and terrorist financing. It applies to a range of entities, including credit institutions, financial institutions, auditors, accountants, tax advisors, gambling operators, as well as to other legal and natural persons trading in goods, to the extent that payments are made or received in cash in an amount of EUR 10 000, regardless of whether payments are made in a single, or via a series of transactions that appear to be linked. While at this early stage, it is difficult to assess if the AML Directive will help to reach the set goal of preventing that the financial system in the Member States is used for money laundering and terrorist financing, it may assist the detection, investigation, and prosecution of these crimes. The Directive brings into force new requirements for customer due diligence, supported by increased obligations to report suspicious transactions and the duty to retain certain categories of personal data.

Repatriation and (perceived) organisational support (POS)

PurposeThe purpose of this paper is to explore the role of and interaction between (potential) repatriation supporters to develop understanding of how this affects the repatriate experience.Design/methodology/approachA (single) case study strategy was employed, using a multiple stakeholder approach, involving 21 in-depth interviews in a large UK-based institution with repatriates, home and host HR managers, international human resource (IHR) practitioners and line managers from both home and host locations.FindingsAlthough line managers, senior managers, family members and third party providers (e.g. relocation agencies, tax advisors) are important for repatriation support, the case study evidence highlights that HR professionals are mainly responsible for the quality of the support delivered by other repatriation supporters. Inadequate support from the headquarters IHR department caused by a lack and unclear information about repatriation procedures and related responsibilities results in insufficient support for home and host HR managers. This negatively impacts repatriates line managers (perceptions of) HR support. Weaknesses in the support chain (headquarter IHR, home and host HR and line managers) are responsible for repatriates (perceived) limited or non-support.Research limitations/implicationsThe small size of our sample, the single case study design and the method precludes generalisation of the findings. However, the authors’ “look inside” increased the understanding of repatriation support and in particular the support quality. By linking this information to the knowledge of previous studies on organisational support and the devolution of human resource management, the authors are able to identify several topics future studies in the field of repatriation management.Practical implicationsIHRM policies have to reflect the role of multiple stakeholders including home and host line managers and HR professionals as well as third party providers and assign clear lines of responsibility to provide a transparent and consistent experience. Repatriates family has to be acknowledged as a stakeholder that has a major influence on repatriation success and failure. Excluding partners and children issues from international career policies has to be considered as a serious HR shortcoming. Second, ensuring timely information regarding return positions. Providing debriefing interviews upon repatriation can help to identify future roles within the organisation. Equally important is exit interviews to explore whether the person has completed an assignment within the previous 24 months and whether this experience has contributed to their decision to leave the organisation. Opportunities to ensure repatriates are being considered for positions as part of the talent pool is crucial. Finally, the authors emphasise the need to acknowledge that third party vendors are part of the repatriation process and must be considered in terms of (perceived) organisational support.Originality/valueThis is one of the first studies that highlights the role and interaction of (potential) repatriation supporters. Specifically, this study contributes to addressing three knowledge gaps: it identifies a lack of communication among HR professionals and between them and line managers as a potential source of insufficient organisational support; the findings highlight HR professionals responsibility for supporting line managers and other repatriation supporters in operational repatriation management; and finally, the results support the assumption that HR professionals and line managers own (non-)experience with working abroad might affect the quality of support policies and practices for repatriates.

Сущность налогового консультирования предприятий и оценка его регулирования

Сущность налогового консультирования предприятий и оценка его регулирования

SOCIAL AND PSYCHOLOGICAL ASPECTS OF TAX CONSULTING IN UKRAINE

Introduction. Increase in the community understand the need for full and timely calculation and payment of taxes and duties and conscious understanding of their importance for the viability of the state, providing qualified and effective consultative assistance to taxpayers acting priority at the state tax consulting and corporate levels. An important role in this context is played by psychological traits taxpayers that understand key aspects of tax consulting. It increases the level of tax literacy and tax culture in society, strengthens economic competitiveness and creates a series of macroeconomic effects. The purpose of the article is the study of social and psychological aspects of functioning and improving tax consulting services in Ukraine. Results. The theoretical aspects of the tax consulting are investigated. The basic indicators of the State Fiscal Service of Ukraine in the field of consulting are analyzed. The psychological traits of the conduct of fiscal and tax advisors are systematized. Deals with the social component of the tax behavior of taxpayers and outlines the reasons prompting them to deviation. Showed the role and place of business taxation in the formation of tax culture. Proved, that the active outreach by SFS of Ukraine will increase the level of tax awareness and create a tax culture in society. Formation and development of the effective market of tax consulting in Ukraine will increase the level of service taxpayers at the corporate level will lead to optimization of fiscal policy and strengthen its social role. Conclusion. The ability to use the tax employees in the work of social and psychological technologies can increase the efficiency of their operations and create the basis for improving the confidence of taxpayers to the tax system in general, increase of tax culture in society, and to create a basis for the functioning of the corporate tax consultancy in Ukraine

The Integrity of the Tax System after BEPS: A Shared Responsibility

The international tax system is the result of the interaction of different actors who share the responsibility for its integrity. States and multinational corporations both enjoy to a certain extent freedom of choice with regard to their tax behaviour – which entails moral responsibility. Making, interpreting and using tax rules therefore is inevitably a matter of exercising responsibility. Both should abstain from viewing tax laws as a bunch of technical rules to be used as a tool without any intrinsic moral or legal value. States bear primary responsibility for the integrity of the international tax system. They should become more reticent in their use of tax as regulatory instrument – competing with one another for multinationals’ investment. They should also act more responsibly by cooperating to make better rules to prevent aggressive tax planning, which entails a shift in tax payments from very expert taxpayers to other taxpayers. Here, the distributive justice of the tax system and a level playing field should be guaranteed. Multinationals should abstain from putting pressure on states and lobbying for favourable tax rules that disproportionally affect other taxpayers – SMEs and individual taxpayers alike. Multinationals and their tax advisers should avoid irresponsible conduct by not aiming to pay a minimalist amount of (corporate income) taxes – merely staying within the boundaries of the letter of the law. Especially CSR-corporations should assume the responsibility for the integrity of the tax system.

International Taxation Core Concepts

The main purpose of International Taxation Core Concepts is to show managers, lawyers, accountants and others how tax laws affect global management decision-making. Part I of the book is a case study (or ‘tax novella’) called La Brienza Winery: Tax Trouble in Wine Country that illustrates how managers confront international tax challenges in the real world. It tells the story of Professor Xavier Montenegro and his tax advice to Dana La Brienza, the owner/manager of a Northern California winery with expanding global operations. Part II of the book contains additional materials on the U.S. and Canadian tax rules governing different cross-border planning strategies, including updates on recent developments. The second edition includes a new chapter on the developing relationship between Xavier and Dana. The attached excerpt provides the table of contents and the first chapter of La Brienza Winery.

Can a Cost Sharing Arrangement Prevent a Tax Shelter Label?

In connection with an ongoing effort of the government to examine certain Microsoft documents, the government on October 12, 2016, stated a filed document that one of the transactions at issue is unquestionably a tax shelter for purposes of section 7525. The significance of that is whether some written communications should be protected from IRS scrutiny by the section 7525 confidentiality privilege that may apply to tax advice between a taxpayer and tax practitioners. Under section 7525(b)(2), written communications will not qualify if they are in connection with the promotion of the direct or indirect participation of the person any tax shelter. This article make the case that various countering briefs filed by Microsoft, KPMG, and certain amici do not tell the full story. They primarily maintain that there can be no tax shelter since the structure includes a cost sharing agreement, which is a structure that has been condoned by regulations for almost forty years. This article suggests that a fuller story must include background information on the Microsoft structuring, of which the cost sharing agreement is merely one piece. With full details regarding the structuring and how Microsoft conducts the relevant operations being unknown, this article draws no conclusion about whether a section 7525 tax shelter label is appropriate. The article importantly notes, though, that the district court's ability to make a reasonable judgment would be best served if the parties provided a full picture of the relevant activities performed by Microsoft and the part played by the cost sharing agreement.

Porezni savjetnici: zamagljen identitet, velika očekivanja

A high degree of engagement between tax authorities and taxpayers is nothing new in tax law but it is an approach that gained in importance towards the end of the 20th century. The last ten years were characterised by co-operative compliance theory. The mentioned theory, among other things, has provoked a process of reviewing the tax advisors' role. Therefore, the relationship between tax authorities and tax advisors has an increasing importance. The article consists of two main thematic parts. The first part introduces a general state and tendencies in the tax advising profession. In the second part, the results of empirical research conducted among tax advisors in Croatia are presented. The aim of the research is to examine how tax advisors in Croatia perceive their role and their relationship with tax authorities as well as to gain useful insight which would contribute to a better understanding of relationships between the participants in the tax-law relationship. The method used for data collection was interview. Results of the research point to several conclusions. Firstly, most tax advisors believe that the tax authorities are distrustful toward tax advisors and are of the opinion that tax advisors mostly help taxpayers to evade their tax obligations. With regard to the attitude of the tax authorities towards taxpayers, they point out that it is an authoritarian relationship dominated by the cop and robber approach. Also, most advisors are of the opinion that their profession lacks a distinctive identity. To conclude, the article provides some recommendations and possible legal and tax policy changes.

A Review of Uganda's Tax Treaties and Recommendations for Action

In June 2014, Uganda announced the temporary cessation of bilateral tax treaty negotiations, and a review of its policy towards such treaties. The main effect of tax treaties is to divide up the ‘rights’ to tax cross-border investment between the state parties, which reduces the possibility that businesses will incur double taxation; in doing so, it places significant curbs on the ability of capital-importing countries, such as Uganda, to tax foreign investors. Uganda’s review follows decisions by developing countries as diverse as Argentina, Mongolia, Rwanda and Zambia to cancel or renegotiate some of their historical tax treaties. These countries, together with some independent commentators, international and non- governmental organisations, have questioned whether the benefits of tax treaties for developing countries outweigh their costs. In Uganda, as elsewhere, tax treaties have always been surrounded by an investment promotion discourse in political debate, yet there is little convincing evidence that they have had a positive effect on investment flows into low-income countries. In contrast, there are some clear aspects of Uganda’s treaties, such as definitions of ‘permanent establishment’ and rules concerning the taxation of capital gains, which cost Uganda significant revenue and are vulnerable to abusive tax planning. A key problem is that Uganda’s negotiating position has been based on the UN model treaty, which embodies a compromise position, rather than an ideal one to be horse-traded during negotiations. The recent East African Community (EAC) and Common Market for Eastern and Southern Africa (COMESA) model treaties also represent compromise positions. This paper uses a comparative analysis of treaties signed by Uganda and other neighbouring countries, combined with interviews conducted with government officials and private sector tax advisers, to assess whether Uganda’s network of tax treaties is fit for purpose, and to recommend how it could be improved through the policy review.

Suicide Prevention in Health Care.

Decreasing suicide rates through health care system change is an example of how improving patient safety warrants psychiatrists’ awareness, training, teamwork, and leadership in system-based solutions. It has been over 15 years since the Institute of Medicine (IOM) report, To Err Is Human: Building a Safer Health System (2), reported that “at least 44,000 people, and perhaps as many as 98,000 people, die in hospitals each year as a result of medical errors that could have been prevented.” In March of 2001, IOM’s next catalyzing report, Crossing the Quality Chasm, concluded that “merely making incremental improvements in current systems of care will not suffice.” These reports inspired the nation’s campaign to improve quality and safety in health care (3). However, adverse events causing morbidity and mortality continue. The Six Sigma comparison of industries ranks the many health care “defects per million opportunities” near that of the Internal Revenue Service tax advice phone-in service; domestic airline flight fatality rates achieve superior Six Sigma safety rates (4). Many of the country’s top sentinel events are mental health related, including restraint-related events, elopements, selfinflicted injuries, and suicides (5). Some of the top sentinel event settings include psychiatric hospitals, psychiatric units, and behavioral health facilities, totaling 19% of all locations for sentinel events since 2004. In comparison, emergency departments account for only 5.4%, and office-based surgery, 0.9%. Approximately 1,500 inpatient suicides occur per year in theUnited States (6). In juxtaposition, themost recent data from aviation fatalities from theNational Transportation Safety Board reveal a total of only 443 aviation deaths (7). If psychiatrists are the pilots of the mental health system, then what can they do in collaboration with others to transform the industry to the next level of safety at a systems level? Many organizations support this system transformation, including IOM, the Agency for Healthcare Research and Quality, the Joint Commission, the American Academy of Child and Adolescent Psychiatry, and the American Psychiatric Association. In addition, the American Board of Medical Specialties is highlighting safety standards by integrating patient safety principles into its program for maintenance of certification (MOC) requirements (9). The American Board of Psychiatry and Neurology is part of this leadership drive (10). Focus will begin attending to MOC safety requirements and providing a review of current clinical safety practice. Patient safety is a vital function of psychiatric services and a core objective of the mental health system. Without safety, there would be neither treatment nor recovery. Suicide is one of the top safety challenges that our health care system faces. Psychiatrists and other mental health clinicians practice standards of care in their provision of suicide risk assessment, risk management, and biopsychosocial treatments. However, in the system of care some failure modes are root causes of suicide and are beyond the realm of the psychiatrist’s assessment and treatment. If there were board exam questions on suicide data and suicide risk assessment, psychiatrists would readily know the answers (noted at the end of this column):

How Will the Court Decide? – Tax Experts’ versus Laymen's Predictions

We conduct a survey of German tax professionals (tax advisors and revenue agents) and laymen to examine whether tax experts more accurately forecast the outcomes of five real cases from the German Federal Fiscal Court. With an average of 2.39 correct predictions among experts and an average of 2.49 correct predictions among laymen, our results reveal no significant difference in forecasting accuracy between the two groups. Additionally, neither general nor task-specific tax expertise increases the experts’ forecasting accuracy. This unpredictability of tax court decisions indicates that accounting rules and taxpayer penalties that rely on accurate predictions of tax court decisions may need to be re-evaluated. Moreover, our results indicate the existence of two types of ‘advisor bias’. First, tax advisors exhibit a significantly higher level of overconfidence in comparison to other experts (i.e. revenue agents) and laymen. In particular, they believe that they correctly predict, on average, 1.52 more cases than they actually do. Second, we find some evidence indicating that tax advisors acting as client advocates form stronger appeal recommendations than revenue agents.