Jerald David August presented "U.S. Companies Making Outbound Investments, A Primer" at the NJ Bar Annual Tax Conference
Discussions included choice of entity decisions for U.S. persons engaging in business operations overseas, including the use of hybrid entities; nexus for foreign tax exposure including treaty provisions such as the permanent establishment rule, taxation of foreign source business income.
Bryan C. Skarlatos presented "IRS Update: Hot Tips On Tax Penalties" at the 2017 AICPA Sophisticated Tax Planning For Your Wealthy Clients Conference
The number of accuracy-related penalties assessed against individual taxpayers increased from 58,366 in 2005 to 553,184 in 2015. That is nearly a 1,000% increase over the past decade! Are there more bad taxpayers? Or, is the IRS just getting more aggressive about asserting penalties? Regardless of the answer, responsible tax practitioners must understand what triggers a penalty assessment and how to protect their clients and themselves against such assessments. This session provided useful tips on how to deal with the IRS when tax penalties raise their ugly head.
Caroline D. Ciraolo participated in a panel titled "The IRS And DOJ Continue To Prioritize Employment Tax Enforcement - Are You And Your Clients Prepared?" at the 2017 Annual Meeting of the California Tax Bar & California Tax Policy Conference
For the last several years, the IRS and the Department of Justice Tax Division have focused their attention on employment tax enforcement. We’ve seen new notices and alerts to taxpayers regarding non-compliance, more field visits by revenue officers, an increase in worker classification audits, a surge in suits for injunctions and motions for contempt, and an escalation of criminal investigations into willful employment tax violations.
With bitcoin trading hitting all-time highs, Ryan Derousseau explores tax-related issues in Money Magazine's recent article, "There's a Hidden Bitcoin Tax You Need to Know About". In a quote from the article:
"You can even buy lunch at a Subway sandwich shop in Allentown, Penn. using bitcoin, or gain access to the VIP room of a “gentlemen’s club” in Las Vegas.
Every year, Super Lawyers selects attorneys who exhibit excellence in the practice of law to either a Super Lawyers or Rising Starts list in each state using a patented selection process. Michael Sardar has been selected because of his outstanding excellence in his practice.
Caroline D. Ciraolo moderated a panel titled "Continuing Enforcement And Disclosure Issues Regarding Foreign Assets" at the ABA International Tax Enforcement and Controversy Conference
On October 27, 2017, Caroline Ciraolo joined an esteemed panel at the ABA International Tax Enforcement and Controversy Conference, including John V. Cardone, Director, Withholding and International Individual Compliance Practice Area, Large Business & International Division, IRS, Nanette L. Davis, Senior Litigation Counsel, U.S. Department of Justice Tax Division, Don Fort, Chief, Criminal Investigation Division, IRS, and Charles Pillitteri, Assistant Division Counsel (International), Small Business/Self-Employed, IRS, to discuss the Continuing Enforcement and Disclosure Issues Regarding Foreign Assets.
Bryan C. Skarlatos presented "How Far Can You Go? Ethical And Penalty Issues In Everyday Tax Practice" at the NYU-SPS 76th Institute On Federal Taxation
The NYU School of Professional Studies Institute on Federal Taxation is designed for the practitioner who must frequently anticipate and handle federal tax matters. It provides high-level updates, practical advice you can implement, and in-depth analysis of the latest trends and developments from leading experts.
Jerald David August presented "Choice Of Entity For Owners Of A Closely Held Business With Tax Legislation On The Horizon" at the NYU 76th Institute on Federal Taxation
This presentation explored the various factors involved in advising clients on choice of entity decisions, including conversions of tax status and their tax impacts to the entity as well as the owners. The speakers compared the taxation and related tax attributes, including ownership attributes, attributable to C or regular corporations, S corporations, limited liability companies, limited partnerships, and general partners.
Bryan C. Skarlatos presented "Ethical Issues Raised By 'Transaction of Interest' Classifications" at the 52nd Annual Southern Federal Tax Institute
In the waning hours of the Obama administration, the IRS published two retroactive “transaction of interest” notices that arguably thwart two statutory inducements: Section 831(b) small captive insurance companies, and syndications of Section 170(h) conservation easements.
Bryan C. Skarlatos participated in a panel titled "Mastering Bitcoin, Blockchain, & Digital Currency Law CLE" at The Rossdale Group Telephonic Seminar
The huge expansion in Bitcoin & digital currencies in states across the nation and globally has led to a significant need for attorneys proficient in the cutting-edge use of related legal and regulatory issues. The laws vary greatly and have been in flux with the proliferation of Fortune 500 companies, governments, and start-ups seeking to take advantage of this growing use of currency. The faculty for this seminar featured several leading authorities on the subject.