Megan L. Brackney participated in the panel titled "Bringing Your Client In From The Cold" at the Quinnipiac University 2nd Annual Criminal Tax Day
Many clients either fail to report items or claim items on their tax returns that have no basis in fact. What do you do with the client who needs to clean up their issues before the IRS funds the issue? This panel reviewed options for cleaning up back tax issues, including amending tax returns and utilizing the voluntary disclosure program, and when practitioners should consider one option over the other.
Megan L. Brackney participated in the panel titled "Dealing With The Undocumented Worker" at the Quinnipiac University 2nd Annual Criminal Tax Day
Businesses that hire undocumented employees have many issues, not the least of which are payroll tax problems, Department of Labor issues and immigration violations. Our panel walked through these issues and what you can do for your client before the IRS shows up, and what can be done after its agents knock on the client’s door.
Caroline D. Ciraolo participated in the panel titled "Fundamentals Of Tax Litigation: Choice Of Forum And Appealing Decisions" at the ABA Section of Taxation 2018 May Meeting
This panel discussed some of the basics of tax litigation; choosing a forum for litigating a tax dispute; and procedures for appealing decisions from the different trial forums. Panelists discussed jurisdictional requirements and limitations of the various courts, differences in discovery practice, trial procedure, drafting litigation documents, and procedures for appealing.
Bryan C. Skarlatos participated in the panel titled "Life Cycle And Tax Implications Of A Cryptocurrency" at the ABA Section of Taxation 2018 May Meeting
This panel followed the life cycle of a cryptocurrency and the tax issues that arise at each stage including the formation of the entity issuing the token, solicitation of investors via a SAFT, token launch and acceptance on an exchange, and tokens held for investment purposes and used similar to fiat currency.
Michael Sardar participated in the panel titled "Reports Of Subcommittees On Important Developments" at the ABA Section of Taxation 2018 May Meeting
Important Developments (Civil) – Sara G. Neill and Michelle F. Schwerin, Capes Sokol Goodman Sarachan PC, St. Louis, MO; Important Developments (Criminal) – Evan J. Davis, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA and Claire Taylor, Colvin & Hallett, Seattle, WA; International Tax Enforcement – Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC and Joseph M. Erwin, Dallas, TX;
Megan L. Brackney participated in the panel titled "Primer On Ethics And Circular 230 Issues For Young Attorneys" at the ABA Section of Taxation 2018 May Meeting
A panel of staff members from the IRS Office of Professional Responsibility and private practitioners discussed basic ethics issues for young lawyers and the sources of guidance that young attorneys should consult, including the ABA Model Rules and Circular 230.
Henry Stow Lovejoy participated in the panel titled “Tax Issues For Banking And Savings Institutions Dealing In Cryptocurrency" at the ABA Section of Taxation 2018 May Meeting
Cryptocurrencies and ICOs continue to proliferate. This panel considered issues pertinent to banks and other financial institutions raised by cryptocurrencies, including amount, character, timing and source of income and deductions from cryptocurrency loans and borrowings, treatment of cryptocurrency derivatives, and reporting and withholding obligations. Additionally, unique tax issues associated with ICOs were also addressed.
Caroline D. Ciraolo participated in the panel titled "Collection Of Title 31 International Penalties" at the ABA Section of Taxation 2018 May Meeting
With the increase in international enforcement efforts and heightened focus on anti-money laundering and anti-tax evasion, individuals and entities are finding themselves subject to substantial civil penalties for failing to report foreign financial accounts and other violations of the Bank Secrecy Act. This panel reviewed the Title 31 civil penalties, the methods by which the United States can collect such penalties, available defenses, and best practices for pursuing collection alternatives.
Caroline D. Ciraolo participated in the panel titled "The Gathering Storm: Grappling With The Impact Of Restitution Orders On Civil Tax Litigation" at the ABA Section of Taxation 2018 May Meeting
In criminal cases involving tax counts, defendants being sentenced frequently wish to show remorse by paying the criminal tax loss prior to sentencing. These payments generally predate any actual civil tax determinations, let alone an IRS assessment. To allow the IRS to assess and collect an amount of restitution as if such amount were tax, Congress, in 2010, amended section 6201(a)(4). The result was that sentencing district court judges could now issue Restitution Orders permitting immediate assessment of the tax loss amount by IRS.
Claude M. Millman quoted in "As City Proceeds with Two Charter Revision Commissions, a Cautionary Tale from Los Angeles", Gotham Gazette
“It’s hard to get the public engaged in a discussion about the city’s charter,” said Claude Millman, who served as a commissioner during the 2001 New York City charter revision commission and who was the executive director for the city’s 1999 commission. “It’s even harder to keep the public involved when charter revision is diffused over two, separate commissions."