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Jerald David August presented "Understanding and Planning for the New Partnership Audit Rules" at the 41st Annual American Institute on Federal Taxation

The presentation focused on the new partnership audit rules and proposed regulations and other guidance issued by the Treasury and IRS.

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Caroline D. Ciraolo presented "A Perspective on IRS Virtual Currency Enforcement Action" at the Blockchain, Accounting, Audit & Tax Conference

This panel focused on recent IRS enforcement activities including the use of John Doe summons to get expansive customer records from a virtual currency exchange. John Doe summons are generally used to obtain information when specific taxpayers cannot be identified in an investigation. 

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Jerald David August quoted in the Tax Notes Article "Partnership Audit Transition Potentially Is ‘Tax Procedure Hell’"

By Nathan J. Richman & Andrew Velarde

The potential for court cases involving new and old partnership audit rules along with early opt-ins to the new rules and partnerships opting out “is my idea of tax procedure hell,” Tax Court Chief Judge L. Paige Marvel said June 16.

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Bryan C. Skarlatos quoted in the Financial Times Article "US intensifies fight against tax evasion by using data mining"

Agents pursue ‘leavers’ who moved Swiss bank accounts to other offshore centres

By Kara Scannell

US tax authorities are intensifying their efforts to find tax evaders and the bankers who assist them, deploying agents to examine reams of data collected from the Panama Papers, Swiss banks and whistleblowers.

The Department of Justice and Internal Revenue Service are tracing accounts shifted by Americans from Switzerland to other countries such as Israel, Singapore and Hong Kong.

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Michael Sardar spoke on the panel "Stepping Lightly: Practical Advice For Handling Ethical And Sensitive Issues In A Civil Audit" at the 9th Annual NYU Tax Controversy Forum

Unaccounted for transactions, unusual corporate deductions, and overly aggressive interpretations of the Internal Revenue Code are hallmarks of a sensitive-issue audit. These are the kinds of issues that keep practitioners awake at night. 

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Jerald David August will present at the 41st Annual American Institute on Federal Taxation

The presentation will focus on the new partnership audit rules and proposed regulations and other guidance issued by the Treasury and IRS. Among the topics will be the election-out rules, the imputed underpayment computation and modifications, the push-out rules, tax litigation impacts as well as the states’ treatment of the new rules.

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Caroline D. Ciraolo spoke on the panel "Tax Compliance and Enforcement Update Part II - Department of Justice Update" at the 9th Annual NYU Tax Controversy Forum

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS and DOJ have been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. This panel provided an update on new developments and priorities across the IRS and DOJ.

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Caroline D. Ciraolo moderated the panel "International Exchange of Information and Evidence Gathering" at the 9th Annual NYU Tax Controversy Forum

In an increasingly globalized economy, taxpayers—from multinational corporations to globe-trotting individuals—can have financial dealings and information relevant to tax enforcement in many different countries. International agreements, including treaties, tax information exchange agreements, automatic exchange agreements, and local laws, dramatically affect whether and how information can be obtained and shared with other countries’ tax authorities. This panel examined the various methods that are used and issues that arise when one country’s tax authorities seek information and evidence within the jurisdiction of another country.

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The New Partnership Centralized Audit Rules Are Coming Soon; Are Your Clients’ Partnership and Operating Agreements Ready? Looking In Particular At the Partnership Audit Provisions

By: Jerald David August

Partnership Centralized Audit Rules Enacted in 2015 Having a General Start Date For Taxable Years Beginning January 1, 2018

The Bipartisan Budget Act of 2015 (the “Budget Act”)  which the President signed into law on November 2, 2015 (as modified by the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), fundamentally changes how the Service will conduct audits of partnerships. The Budget Act repeals the partnership audit provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) and electing large partnership regimes and replaces them with a new set of rules for partnership audits and judicial review of partnership audit adjustments under a centralized or consolidated partnership audit regime.  While the new rules may have had a specific purpose in mind, i.e., of streamlining partnership audits and raising revenues from incorrect tax positions taken by large partnerships, the statutory language and principles in the new legislation suffer from several structural defects, some of which are fundamentally inconsistent with the long-standing principles of partnership taxation under Subchapter K.  

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Caroline D. Ciraolo spoke on the panel "Tax Enforcement Update: Significant Issues" at the 33rd Annual Texas Federal Tax Institute

This event consisted of a lively discussion among former high ranking government representatives (including a former IRS Commissioner, IRS Chief Counsel, and Acting Assistant Attorney General [Tax]) with the IRS Associate Chief Counsel (Procedures and Administration) and IRS Area Counsel (SB/SE) regarding current IRS enforcement issues in an era of budget cutbacks and tax policy and enforcement challenges.

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