Press Room

Court Decision Overturning Circular 230 Restrictions on Contingent Fees is Final

Press Release Sep 24, 2014

Dallas, Texas – Ryan, a leading global tax services firm with the largest indirect and property tax practices in North America, today announced that the United States Department of Justice Tax Appellate has elected not to appeal the court ruling in favor of Ryan against the United States Secretary of the Treasury and the Commissioner of the Internal Revenue Service (IRS). That ruling invalidated and permanently enjoined the IRS from enforcing the Circular 230 restrictions prohibiting the use of contingent fee arrangements for ordinary refund claims and amended returns. As a result, the decision is now final.

The suit was filed by Ryan Executive Vice President and Vice Chairman Gerry L. Ridgely, Jr. in 2012 to challenge the Circular 230 provisions generally prohibiting attorneys, certified public accountants (CPAs), and other practitioners from entering into contingent fee arrangements for services rendered in connection with certain matters before the 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.

“This long-fought battle to protect taxpayers and their representatives from the IRS’s efforts to limit their ability to pursue valid claims is finally over,” said Gerry L. Ridgely, Jr., Executive Vice President and Vice Chairman of Ryan. “We are very gratified that taxpayers, and not the IRS, now have the right to determine the fee arrangement between themselves and their representatives.”

“Ryan is proud to have led the charge to permanently overturn these overreaching IRS regulations,” said G. Brint Ryan, Chairman and CEO of Ryan. “We will continue to aggressively defend the rights of our clients, as well as taxpayers everywhere, from unlawful and burdensome tax regulations.”

For more information about this ruling, please see the Order and Memorandum Opinion.

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 4,700 professionals and associates serves over 29,000 clients in more than 75 countries, including many of the world’s most prominent Global 5000 companies. More information about Ryan can be found at


Melodie Elliott
Director, Content & Communications Marketing