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Caroline D. Ciraolo presented "The Impact Of Global Tax Enforcement" at the 2018 E.L. Wiegand Lecture

Countries around the world are calculating their respective tax gaps and increasing their investment in civil tax enforcement as information regarding offshore tax evasion takes center stage with the surge of whistleblowers and data leaks. At the same time, law enforcement officials are reviewing information obtained from various sources to identify individuals and entities engaged in tax evasion and to pursue criminal investigations.

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Caroline D. Ciraolo participated in a panel titled "Evolving Constraints On Tax Administration At The IRS" at the 2018 ABA Taxation Section Midyear Meeting in San Diego, CA

The IRS and Treasury Department have faced increasing budget and legal constraints over the past few years. Treasury is also experiencing limits on its rulemaking, both from the current Presidential Administration and from courts applying administrative law, such as with respect to the anti-inversion regulations. IRS budget constraints and workforce decreases started around 2011, and the IRS’s image has suffered following a 2013 report from the Treasury Inspector General for Tax Administration (TIGTA) on the IRS’s review of applications for determination of tax-exempt status.

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Henry Stow Lovejoy participated in a panel titled "Equity-Based Mortgages – Debt/Equity/Derivatives Or A Combination Thereof?" at the 2018 ABA Taxation Section Midyear Meeting in San Diego, CA

A growing number of lenders offer mortgages that are designed to share the risk and reward of depreciation/appreciation in real estate values between the lender and borrower. For the borrower to deduct payments as mortgage interest, the instrument must be a debt instrument secured by real estate.

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Michael Sardar presented "Offshore Compliance Subcommittee Of The ABA’s Committee On Civil And Criminal Tax Penalties Report" at the 2018 ABA Taxation Section Midyear Meeting in San Diego, CA

This meeting brought together the nation’s leading tax practitioners to discuss current issues, topics and legislation. This two-day meeting offered the resources and information needed on the latest developments, strategies and techniques to represent and meet the needs of your clients and take your practice to the next level. 

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Caroline D. Ciraolo moderated a panel titled "The New Wave Of Fraud Referrals – IRS Collections" at the 2018 ABA Taxation Section Midyear Meeting in San Diego, CA

Taxpayers with unpaid tax liabilities who take steps to minimize or conceal their income and assets are the subject of increased scrutiny by the Internal Revenue Service and the Department of Justice. IRS Field Collections and Criminal Investigation are working together to train revenue officers to identify fraudulent conduct and refer collection matters for criminal investigation, and the Tax Division has identified this area as a priority for criminal enforcement.

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Pros and Cons of Voluntarily Disclosing Past Wrongs

By Wendy Abkin, George Abney, and Caroline D. Ciraolo
Tax Executive Institute 
February 2018

TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION

Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince of Denmark seeking to avenge his father’s death, the choice was action or inaction, and ultimately life or death. Fortunately, most tax problems do not have such grave outcomes. Seemingly inconsequential tax errors can, however, lead to severe financial consequences. And, remote as it may seem, the prospect of imprisonment for tax crimes cannot be overlooked. When a past wrong is discovered, what should you do?

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Kostelanetz & Fink Welcomes New Tax Lawyer

Kostelanetz & Fink is pleased to announce that Deborah Plum joined the firm in February as an associate. Ms. Plum came to the firm from the tax department of Simpson Thacher & Bartlett LLP.

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Caroline Rule breaks down The Current Jurisprudence On The Fifth Amendment’s Act Of Production Privilege

In a recent scholarly article in the ABA’s The Tax Lawyer, Caroline Rule answers the question of whether United States v. Greenfield was a triumph of the Fifth Amendment’s act of production privilege or confirmation that the privilege can be entirely abrogated by any act of Congress or even by a Treasury regulation.

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Jerald David August presented "Impact On: Closely Held Corporations" for the Impact of the New Tax Act Video Webcast

This presentation focused on the different treatments of closely held S corporations, C corporations, and their shareholders, under the new law. Topics included tax rates, conversions from C to S or S to C status, and the benefits of C corporations engaging in offshore business operations.

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Sharon L. McCarthy presented "Best Practices For Representing Whistleblower Targets" at the 9th Annual Criminal Tax Enforcement Forum in Paramus, NJ

The 9th Annual Criminal Tax Enforcement Forum brought together government representatives and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax prosecutions in New Jersey.

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