Caroline D. Ciraolo interviewed Richard E. Zuckerman, Esq. for the "Department of Justice Update" at the NYU SCPS 11th Annual Tax Controversy Forum
Richard E. Zuckerman, Esq., Principal Deputy Assistant Attorney General, Tax Division, US Department of Justice, Washington, DC
Interviewer: Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
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The NYU School of Professional Studies is pleased to present the 11th Annual Tax Controversy Forum. The Tax Controversy Forum brings together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, and civil and criminal tax penalties.
Enforcement is an essential part of our federal tax system. The Tax Controversy Forum is an opportunity to stay current on new developments, exchange ideas, and share practice tips that can contribute to a better functioning system. Participants qualify for CPE and CLE credits. As a premier educational institution, the NYU School of Professional Studies is committed to providing the highest standard of professional enrichment.
Christopher M. Ferguson moderated a panel titled "Following the Money: The Ins and Outs of Construction Industry Audits and Investigations" at the NYU SCPS 11th Annual Tax Controversy Forum
Construction projects often involve large amounts of money changing hands among a large number of people creating a situation that is ripe for mistakes and even fraud. In response, the government has developed investigative technics specifically for uncovering tax non-compliance in the construction industry. This panel reviewed how the government approaches audits and investigations in the construction industry and practical tips for representing taxpayers who are faced with having to explain where their money came from and where it went.
Caroline D. Ciraolo moderated a panel titled "How Well Do Your Secrets Travel? Understanding the Scope of Privileges in Crossborder Audits and Investigations" at the NYU SCPS 11th Annual Tax Controversy Forum
International tax enforcement is a top priority of the IRS and the Department of Justice. Audits and investigations routinely involve the collection of information, documents, and testimony outside the United States, leaving tax practitioners to determine what, if any, privilege applies and how those privileges can be preserved in various jurisdictions. This panel of experienced tax controversy attorneys addressed common privileges that arise in tax matters, the holder and scope of those privileges, the extent to which such privileges can be waived or set aside, and how to navigate these waters in foreign and cross-border audits and investigations.
Brian Ketcham participated in a panel titled "International Information Return Litigation" at the Agostino & Associates Tax Controversy Update
Caroline D. Ciraolo and Michael Sardar Participated In A Panel Titled "FBAR & FATCA: The Crackdown On Unreported Foreign Assets Continues" at The AICPA ENGAGE 2019 Conference
U.S. taxpayers and residents are required under the Internal Revenue Code and the Bank Secrecy Act to report their relationship to foreign accounts and assets on an annual basis. The IRS and the Department of Justice have significantly increased enforcement of these reporting requirements through criminal prosecutions and the imposition of crushing civil penalties that can come when taxpayers are not compliant. This panel explored the current state of IRS and DOJ civil and criminal enforcement with respect to taxpayers who have not complied with FBAR (Report of Foreign Bank and Financial Accounts) and FATCA (Foreign Account Tax Compliance Act) reporting requirements. The panel also covered pathways to compliance for the non-compliant taxpayer, including the IRS’s Voluntary Disclosure Practice.
CAROLINE D. CIRAOLO AND BRYAN C. SKARLATOS PARTICIPATED IN A PANEL ON "IRS CONTROVERSIES" AT THE AICPA ENGAGE 2019 CONFERENCE
As IRS enforcement becomes more automated, the need for trained representatives who know what to do and when to do it has never been greater. This panel covered the mechanics of representing taxpayers before the IRS, including exam and collections, so that attendees can identify and understand when taxpayers need help, and how to go about the process of helping them resolve their IRS issue.
1) Explain the process for challenging an exam issue with the IRS
2) Understand the IRS collection process
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Caroline D. Ciraolo and Bryan C. Skarlatos participated in a panel on "IRS Exams and Appeals" in the IRS Workshop at the AICPA ENGAGE 2019 Conference
As IRS enforcement becomes more automated, the need for trained representatives who know what to do and when to do it has never been greater. This panel covered the mechanics of representing taxpayers before the IRS, including Exam, Appeals and Collections, so that attendees could identify and understand when taxpayers need help, and how to go about the process of helping them resolve their IRS issue. This session was covered in 2 parts: 1:00 - 3:00 pm: Part 1 - Examinations and Appeals (Bryan Skarlatos and Caroline Ciraolo) 3:00 - 5:00 pm: Part 2 - IRS Collections (Eric Green, Robert McKenzie and Paul Mamo, IRS Director of Collections).
1. Understand the examination process
2. Identify opportunities to challenge an examiners findings
3. Explain the process for appealing from an IRS examination
4. Understand the IRS collection process
5. Explain the options taxpayers have to resolve an outstanding tax debt
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By: Jay R. Nanavati
Expert Analysis - Opinion
In the wake of the Mueller investigation and the U.S. Department of Justice Office of the Inspector General’s 2016 “Audit of the National Security Division’s Enforcement and Administration of the Foreign Agents Registration Act,” Attorney General William Barr and DOJ National Security Division head John Demers have signaled an increased appetite for enforcing alleged Foreign Agents Registration Act registration violations more aggressively, and members of Congress have been agitating for the DOJ to do just that.
Claude M. Millman quoted in "Students Admitted to Elite Schools Through Diversity Push Do Well Academically, City Data Show," Wall Street Journal, Regarding Lawsuit Handled by K&F
The new data came in response to an appeal by seven students who said the recent expansion of Discovery had unfairly denied them seats in the specialized schools. They asked the state commissioner this spring to ensure they get spots and declare the city’s implementation of Discovery unlawful.
For this fall, the mayor has vastly expanded the Discovery program, which offers seats and free summer tutoring to disadvantaged students who score below the test-score cutoff for regular acceptance. The mayor roughly doubled the size of Discovery, to about 500 seats this fall, or about 13% of specialized high school spots in ninth grade. That growth has sparked an outcry from parents who say their high-scoring children were edged out by Discovery students with lower exam scores. The mayor plans for Discovery students to have 20% of seats in fall of 2020. He also restricted eligibility to students from certain high-poverty middle schools.
The petitioners claim the city ignores language in state law requiring that Discovery operate “without in any manner interfering with the academic level” of the sought-after high schools.
Their lawyer, Claude Millman, rebutted the city Department of Education’s GPA analysis last week. He said the average GPA for Discovery students at a school can mask how individuals may have floundered, and their cohorts were too small to draw conclusions. Further, he said their accomplishments didn’t reflect how well a broader group with lower entrance exam scores will do in the bigger program.