Press Room

Ryan Challenges Constitutionality of Federal Regulation Commonly Known as Circular 230

Press Release Apr 12, 2012

Dallas, Texas – Ryan, a leading global tax services firm with the largest indirect tax practice in North America, today announced that the Firm has filed suit challenging the provisions of Title 31, Section 10, of the Code of Federal Regulations, commonly known as Circular 230. In 2007, Circular 230 was revised to generally prohibit attorneys, CPAs, and other practitioners from entering into contingent fee arrangements for services rendered in connection with any matter before the Internal Revenue Service (IRS), including the preparation and filing of claims for refunds after a taxpayer has filed its original tax return, but before the IRS has initiated an audit of the return. Before the 2007 revision, Circular 230 prohibited contingent fee arrangements for preparing original returns, but permitted the use of contingent fee arrangements for services rendered in connection with the preparation and filing of refund claims if the practitioner reasonably anticipated that the claim would receive substantive review by the IRS.

Ryan’s legal challenge seeks a declaratory judgment that the Circular 230 provisions prohibiting the use of contingent fee arrangements in the preparation and filing of ordinary refund claims and any related representation before the IRS are unconstitutional, exceed the scope of the authorizing statute, and thereby warrant a permanent injunction against the prohibition. The Firm is represented by the law firm Morrison & Foerster, LLP.

"Ryan is leading the charge against regulatory overreach that negatively impacts the ability of taxpayers with bona fide refund claims to obtain representation to pursue their statutory right to a tax refund," said G. Brint Ryan, Chairman and CEO of Ryan. "Ryan will continue to aggressively defend our rights and the rights of our clients to engage advisors in whatever manner they so choose."

For more information about this case, please see the Complaint and related materials.

About Ryan

Ryan, an award-winning global tax services and software provider, is the largest Firm in the world dedicated exclusively to business taxes. With global headquarters in Dallas, Texas, the Firm provides an integrated suite of federal, state, local, and international tax services on a multijurisdictional basis, including tax recovery, consulting, advocacy, compliance, and technology services. Ryan is an 11-time recipient of the International Service Excellence Award from the Customer Service Institute of America (CSIA) for its commitment to world-class client service. Empowered by the dynamic myRyan work environment, which is widely recognized as the most innovative in the tax services industry, Ryan’s multidisciplinary team of more than 4,800 professionals and associates serves over 30,000 clients in more than 80 countries, including many of the world’s most prominent Global 5000 companies. More information about Ryan can be found at


Melodie Elliott
Director, Content and Communications Marketing