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Caroline D. Ciraolo quoted in Tax Notes article entitled "Another District Court Weighs in Favor of FBAR Survivability"

In a recent Tax Notes article by Andrew Velarde entitled “Another District Court Weighs in Favor of FBAR Survivability, Caroline Ciraolo reacted to recent rulings on whether penalties for willful failure to file foreign bank account reports can survive the death of the nonfiler. As Caroline noted, the court’s remedial determination ignores a decade of practice in how the civil FBAR penalty has been imposed.

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Focus on IRS Tax Fraud Enforcement

By Megan L. Brackney
Tax Notes Federal
April 27, 2020 

Given that combating tax fraud is a top agency priority, it is a good time to review the law and procedures related to tax fraud. In this article, Megan Brackney discusses the ways the IRS identifies and addresses fraud, the consequences of committing tax fraud, and some tips for practitioners.

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Caroline D. Ciraolo and Bryan C. Skarlatos quoted in Tax Notes article entitled "Texas Law Firm Must Comply With IRS John Doe Summons"

Caroline D. Ciraolo and Bryan C. Skarlatos were quoted in Tax Notes article entitled "Texas Law Firm Must Comply With IRS John Doe Summons,” regarding a recent Fifth Circuit ruling upholding an order “requiring a Texas law firm to turn over information on clients with offshore structures in response to an IRS John Doe summons,” according to the article.

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Bryan C. Skarlatos quoted in New York Times article entitled "From Afar, a Fugitive in the Knoedler Art Fraud Gives His Defense"

Kostelanetz & Fink partner Bryan Skarlatos was quoted and his photograph was featured in the New York Times this weekend regarding an art fraud case that has been described as “one of the largest art world scandals of recent times.”  Mr. Skarlatos represents one of the co-conspirators in the case. 

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The New Exemption from Required Information Reporting: Revenue Procedure 2020-17 Provides Relief for Certain Tax-Favored Foreign Trusts

By Nicholas S. Bahnsen
The CPA Journal
April 2020 Edition

In March 2020, the IRS announced an exemption to the information reporting requirements applicable to foreign trusts. Under this exemption, qualified individuals no longer need to report transactions with or ownership of applicable tax-favored foreign trusts on Forms 3520 and 3520-A. This article outlines the new exemption and the special procedures for requesting an abatement or refund of penalties previously assessed with respect to these tax-favored foreign trusts, and serves as a reminder that taxpayers may have still other filing and reporting requirements related to these trusts that remain unaffected by the exemption.

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Caroline Ciraolo and Jay Nanavati Selected as 2020 Washington DC Super Lawyers in Areas of Tax and White-Collar Criminal Defense

WASHINGTON, D.C. (April 17, 2020) – Kostelanetz & Fink is pleased to announce that partners Caroline D. Ciraolo and Jay R. Nanavati have been selected for inclusion on the 2020 Washington DC Super Lawyers list. Ciraolo, who was previously included on the list in 2018 and 2019, was recognized for her excellence in tax law. Nanavati, who was also listed in 2019, is ranked as a top white-collar criminal defense attorney. Super Lawyers describes itself as “a rating service of outstanding lawyers from more than 70 practice areas who have attained a high-degree of peer recognition and professional achievement.”

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International Enforcement: What’s Old, What’s New and What We Can Expect

By Caroline D. Ciraolo
Journal of Tax Practice and Procedure
Spring 2020 Edition

At the 35th Annual UCLA Extension Tax Controversy Institute, Caroline D. Ciraolo and her fellow panelists addressed international tax compliance and enforcement, including what’s old, what’s new and what we can expect going forward.

“We cannot continue to operate in the same ways we have in the past, siloing our information from the rest of the world while organized criminals and tax cheats manipulate the system and exploit vulnerabilities for their personal gain. The J5 [Joint Chiefs of Global Tax Enforcement] aims to break down those walls, build upon individual best practices, and become an operational group that is forward-thinking and can pressurize the global criminal community in ways we could not achieve on our own.” Don Fort, Chief of IRS Criminal Investigation (July 2, 2018).

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Bryan C. Skarlatos quoted in Law360 Tax Authority article entitled "New Exec Could Help IRS Efficiently Tamp Down Tax Schemes"

Bryan C. Skarlatos quoted in Law360 Tax Authority article entitled "New Exec Could Help IRS Efficiently Tamp Down Tax Schemes,” which explores how the “creation of a tax scheme promoter investigation coordinator role and a new fraud enforcement unit could help the cash-strapped agency more efficiently police tax schemes by conserving resources.”

 

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IRS Expands Extension of Tax-Related Deadlines Due to Novel Coronavirus (COVID-19)

In its continued response to the coronavirus pandemic, the IRS issued on April 9, 2020, Notice 2020-23, which extends various tax-related deadlines that were not previously extended by IRS Notice 2020-18 and its related Frequently Asked Questions (“FAQs”). 

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Bryan C. Skarlatos quoted in Law360 Tax Authority article entitled "Tax Pros Fear IRS Appeals Cases May Suffer During Pandemic"

Bryan C. Skarlatos quoted in Law360 Tax Authority article entitled "Tax Pros Fear IRS Appeals Cases May Suffer During Pandemic." The article notes that IRS Appeals cases may be impacted by the inability of Appeals employees to hold face-to-face meetings during the coronavirus pandemic, among other constraints on the office.

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