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Caroline Ciraolo Spoke on Panel Entitled "IRS International Tax Enforcement in a Post OVDP World" at 15th Annual International Tax Institute on October 18, 2019

The University of San Diego School of Law - Procopio International Tax Institute gathered the most prominent international tax professionals including numerous government attorneys. The conference addressed new developments in the law, specifically including newly proposed and final Treasury Regulations. This year’s conference placed a lot of focus on the international new U.S. federal tax reform, the so called Tax Cuts & Jobs Act ("TCJA").

The conference was held October 17-18, 2019, on the University of San Diego campus at the Joan B. Kroc Institute for Peace and Justice.

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Bryan C. Skarlatos participated in a panel titled "Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know" at PLI's Tax Strategies Conference 2019

PLI Conference on Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2019

Bryan C. Skarlatos and Kathleen M. Pakenham discussed ethics rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit; the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.

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Caroline Ciraolo Spoke on Panel Entitled "Identifying the Line Between Avoidance and Evasion: Global Criminal Tax Enforcement" at 15th Annual International Tax Institute on October 17, 2019

The University of San Diego School of Law - Procopio International Tax Institute gathered the most prominent international tax professionals including numerous government attorneys. The conference addressed new developments in the law, specifically including newly proposed and final Treasury Regulations. This year’s conference placed a lot of focus on the international new U.S. federal tax reform, the so called Tax Cuts & Jobs Act ("TCJA").

The conference was held October 17-18, 2019, on the University of San Diego campus at the Joan B. Kroc Institute for Peace and Justice.

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Megan L. Brackney participated in the panel "Recent Developments in Innocent Spouse Litigation," at the ABA Tax Section 2019 Fall Meeting

Relief from Joint and Several Liability is a complex area of tax practice. This panel covered recent developments in innocent spouse litigation and administrative procedures. We discussed administrative options for relief where there is no valid joint return. Over the past year innocent spouse litigation has touched on important issues including the limits of Tax Court jurisdiction and the proper scope and standard of review when 6015 relief is requested within a CDP appeal. The Taxpayer First Act introduces additional complexity and uncertainty.

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Paul Butler Participated in the Panel "Ethics/ Ethical Considerations for Advising and Representing Clients on Cannabis and Cryptocurrency" at the ABA Tax Section 2019 Fall Meeting

Emerging laws relating to cannabis and cryptocurrency are creating novel questions for tax practitioners.  These include potential questions relating to lack of guidance, new technologies, and tension between Federal and State laws.  This panel explored the developing tax law related to cannabis and cryptocurrency, and it discussed ethical considerations for tax practitioners assisting clients in these areas.

 

 

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Michael Sardar Participated in the Panel "Reports of Subcommittees on Important Developments: Offshore Compliance and Enforcement" at the ABA Tax Section 2019 Fall Meeting

Michael Sardar participated in a discussion of offshore compliance and enforcement, as part of a larger panel on subcommittee reports on important developments. 

Offshore Compliance and Enforcement Panelists: Arielle Borsos, Caplin & Drysdale, Chtd, Washington, DC, Victor Jaramillo, Caplin & Drysdale, Chtd, Washington, DC, Michael Sardar, Kostelanetz & Fink LLP, New York, New York.

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Caroline D. Ciraolo Chaired The Program Section On Civil and Criminal Tax Penalties at the ABA Tax Section Fall 2019 Meeting

Caroline D. Ciraolo chaired a program section on civil and criminal tax penalties. Panel titles include "Reports of Subcommittees on Important Developments" (which will contain a subsection on offshore compliance and enforcement), "Voluntary Disclosures in California," "To Err is Human, to Forgive Divine: A Guide to Reasonable Cause And Other Defenses to Form 3520 Penalties," "Cryptocurrency - IRS Enforcement Efforts To Ensure Compliance," and "The Evil that Men Do Lives After Them: When is an Executor or Fiduciary Personally Liable for Taxes of Another?

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Robert M. Russell participated in the Panel "Everything You Need to Know About the Application of Section 163(j) to Financial Institutions" at the ABA Tax Section 2019 Fall Meeting

Robert M. Russell participated in a panel about the influence which new regulations will have on financial institutions. On 26 November 2018, Treasury and IRS released proposed regulations under section 163(j), which was modified in December 2017 by TCJA. Section 163(j) and the regulations thereunder have significant impact on financial institutions. This panel reviewed the potential application of the rules to financial institutions and put forth policy considerations and planning points.

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Yoram Keinan Moderated the Panel "Everything You Need to Know About the Application of Section 163(j) to Financial Institutions"

Yoram Keinan moderated a two part panel about the influence which new regulations will have on financial institutions. On 26 November 2018, Treasury and IRS released proposed regulations under section 163(j), which was modified in December 2017 by TCJA. Section 163(j) and the regulations thereunder have significant impact on financial institutions. This panel reviewed the potential application of the rules to financial institutions and put forth policy considerations and planning points.

 

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Paul Butler Participated in the Panel "Tax Practice Management/ California’s New Rules of Professional Conduct" at the ABA Tax Section Fall 2019 Meeting

In 2018, the California Supreme Court approved a comprehensive re-write of its rules of professional conduct. California has now joined the other 49 states in adopting ethics rules patterned after the ABA Model Rules of Professional Conduct, effective November 1, 2018. The rules are binding on all attorneys licensed by the California State Bar and, importantly, may apply to non-California lawyers who practice in the state. Our panel discussed the new rules, including how they apply to tax practice, including where they may conflict with Circular 230, and where they differ from the ABA rules. The discussion emphasized how the ethical standards that apply to California attorneys have changed.

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