Jerald David August Presented The ALI Webcast "The New Partnership Audit Rules: How Will They Impact Privately-Owned Businesses And Family Partnerships?"
This webcast included an inside look at the new centralized partnership audit regime and the challenges the IRS is addressing in the final regulations. Attendees heard a key IRS drafter of the proposed regulations in a give-and-take discussion with experienced counsel as he explained how the regulations are intended to work and explored the problem areas still under review. The panelists also examined issues in drafting and revising partnership agreements in response to the new rules.
Megan L. Brackney spoke on the panel "Sentencing In Tax Prosecutions: The Latest Developments And Most Important Considerations" at the ABA Section of Taxation Fall Meeting
Attendees took advantage of the opportunity to meet with the country’s leading attorneys and government officials to discuss the latest federal tax policies, initiatives, regulations, legislative forecasts and planning ideas.
Jerald David August presented "ASC 740-10 (FIN 48) and Uncertain Tax Positions; IRS’ Ability to Summons Tax Accrual Workpapers" at the Long Island Tax Executives Institute
Mr. August shared his extensive knowledge on the subjects with those in attendance.
This panel gave attendees the opportunity to meet with the country’s leading attorneys and government officials to discuss the latest federal tax policies, initiatives, regulations, legislative forecasts and planning ideas.
Henry Stow Lovejoy spoke on the panel "Beyond Bitcoin: Blockchain and the Tax System" at the ABA Section of Taxation Fall Meeting
Blockchain, a distributed ledger technology, promises to change the way banks and other industries do business. This panel provided an introduction to blockchain and then discussed ways in which blockchain may change the determination and collection of taxes.
Caroline D. Ciraolo participated in a panel titled "Tax Defense" at the NACDL 13th Annual White Collar Seminar "Defending The White Collar Case: In & Out Of Court"
With nearly 5,000 federal criminal offenses, and hundreds of thousands of regulations that can be punished criminally, the power of the federal prosecutor has never been stronger. Many of these offenses are vague on their face, others can be stretched beyond recognition, and nearly all are connected to the ever-increasing Sentencing Guidelines. Prosecutors are armed with broad charging discretion, and discovery rules that consistently favor the government. For those accused of white collar crime, this is their reality.
Caroline D. Ciraolo delivered a Keynote Address at the 35th International Symposium on Economic Crime in Cambridge, England
Ms. Ciraolo delivered a keynote address to those in attendance.
Caroline D. Ciraolo participated in a panel titled “U.S. International Tax Enforcement And Compliance” at the 35th International Symposium on Economic Crime in Cambridge, England
Caroline D. Ciraolo shared her extensive knowledge on the subjects with those in attendance. Panel members are shown below.
The Supreme Court will decide a case, United States v. Marinello, 839 F.3d 209 (2d Cir. 2016), this term on the proper reach of the tax obstruction-of-justice statute, 26 U.S.C. § 7212(a). Many practitioners believe that the courts have granted prosecutors too much discretion in applying the statute to taxpayers’ efforts to frustrate the IRS’s assessment and collection of taxes. Others believe that the courts have interpreted the statute correctly.
In a quote from the article:
Jay R. Nanavati of Kostelanetz & Fink LLP said, “The statute’s fine on its face. It does not criminalize accidents.” Nanavati added, “[t]he remedy [that many practitioners are] seeking, a requirement of proof of knowledge of an investigation, doesn’t address their concern. I just don’t know how the requirement of knowledge of the existence of an investigation substantially reduces the risk of criminalizing negligent destruction of records or aggressive tax planning,” he said. “Maybe ‘corruptly’ is not a high enough level of mens rea, but I’m comfortable with it.”
In early September, attorneys from Kostelanetz & Fink, LLP are scheduled to meet with Chinese International Tax Delegation. The event will include a variety of topics and a round table discussion.