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Sharon L. McCarthy & Antonio X. Molestina Were Recognized by the Fordham Law School Ferrick Center for Social Justice with the Spirit of Service Award on October 21, 2019

Sharon L. McCarthy '89 and Antonio X. Molestina '89 were recognized at the Fordham Law School Ferrick Center for Social Justice's 2019 Awards and Benefit Reception with the Spirit of Service Award on October 21, 2019 at Mutual of America, 320 Park Avenue, New York, NY. 

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Caroline Ciraolo Spoke on the Panel Entitled "IRS International Tax Enforcement in a Post OVDP World," at the 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 on the panel entitled "Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know," at PLI's Tax Strategies Conference 2019 on October 18, 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 the Panel Entitled "Identifying the Line Between Avoidance and Evasion: Global Criminal Tax Enforcement," at the 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 on the panel entitled "Recent Developments in Innocent Spouse Litigation," at the ABA Tax Section 2019 Fall Meeting on October 5, 2019

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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Caroline D. Ciraolo Chaired The Program Section On Civil and Criminal Tax Penalties at the ABA Tax Section Fall 2019 Meeting on October 5, 2019

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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Michael Sardar Participated on the Panel Entitled "Reports of Subcommittees on Important Developments: Offshore Compliance and Enforcement," at the ABA Tax Section 2019 Fall Meeting on October 5, 2019

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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Paul Butler Participated on the Panel Entitled "Ethics/ Ethical Considerations for Advising and Representing Clients on Cannabis and Cryptocurrency," at the ABA Tax Section 2019 Fall Meeting on October 5, 2019

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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Robert M. Russell participated on the Panel entitled "Everything You Need to Know About the Application of Section 163(j) to Financial Institutions," at the ABA Tax Section 2019 Fall Meeting on October 4, 2019

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 entitled "Everything You Need to Know About the Application of Section 163(j) to Financial Institutions," on October 4, 2019

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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