End of Circular 230 Disclaimers & Move Towards Reasonableness
Summary Everyone is happy that Circular 230 disclaimers have been nixed in conjunction with the end of the Covered Opinion rules. The new Circular 230 rules covering written advice install a number of reasonableness inquiries, which utilize a new “reasonable practitioner” standard. The new principle based standards are “more straightforward, simpler, and can be applied…