Michael Sardar participated in the panel titled "Reports Of Subcommittees On Important Developments" at the ABA Section of Taxation, May Tax Meeting
Important developments in Offshore Compliance and Enforcement.
Caroline D. Ciraolo and Megan L. Brackney participated in the panel titled "Are Your Secrets Safe? A Discussion Of The Scope, Application And Protection Of Legal Privileges In The US And Abroad" at the ABA Section of Taxation, May Tax Meeting
Information is power and, in civil audits and criminal investigations, the government seeks to identify and obtain as much information as possible. To the extent such information falls within a recognized legal privilege, it is up to counsel for the taxpayer or target to timely and properly assert the applicable privilege and defend that privilege if the government seeks to compel production. This panel of experienced tax litigation and controversy attorneys addressed the 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 jurisdictions and cross-border investigations.
CAROLINE D. CIRAOLO PARTICIPATED IN THE PANEL TITLED "COLLECTION-BASED TAX CRIMES" AT THE ABA SECTION OF TAXATION, MAY TAX MEETING
Fraud referrals for collection-based tax crimes are on the rise as the IRS seeks to close the tax gap. This panel provided current statistics on, and review of, the tax crimes most likely to be encountered in collection, including willful failure to collect tax, fraud and false statements, and attempts to interfere with the administration of the internal revenue laws. The panelists also discussed practical approaches to handling civil collection cases with criminal implications and how to navigate a criminal collection case.
Yoram Keinan and Stow Lovejoy participated in the panel titled "The Current State of the Economic Substance Doctrine and its Effect on Financial Institutions" at the ABA Section of Taxation, May Tax Meeting
The economic substance doctrine was “codified” in 2010, effective for transactions after March 31, 2010, and a new strict liability penalty added for economic substance understatements. While the IRS and Treasury provided initial guidance on the application of the codified doctrine and the penalty, only a handful of cases have considered post-codification transactions. This panel discussed how the economic substance doctrine has developed since codification and the extent to which the doctrine and the penalty should concern financial institutions in planning and examinations.
Michael Sardar participated in the panel "Asset Protection And Offshore Assets: Hide And Seek In The World Of Divorce" at the AAML/BVR National Divorce Conference
Brought to you by the American Academy of Matrimonial Lawyers (AAML) and Business Valuation Resources (BVR), the National Divorce Conference brought together the leading matrimonial attorneys and financial experts for the only event of its kind.
Paul Butler participated in the panel titled "Statutes of Limitations in Tax Litigation: Friend or Foe?" at the ABA Section of Taxation, May Tax Meeting
Statutes of limitations are an important, but often overlooked, aspect of tax litigation that can work to the advantage or the detriment of a party. Most practitioners are familiar with the general three-year period of limitation on assessment, as well as basic exceptions, including those for a false return, no return, or a substantial omission of gross income. This panel addressed more nuanced rules affecting statutes of limitations in tax, including the interplay of section 6511(a) and (b) in refund suits (and, as appropriate, Tax Court litigation), the failure to notify the IRS of certain foreign transfers, and the failure to disclose listed transactions. The panelists also discussed strategies for navigating statute of limitation issues in litigation, as well as the effect of the government shutdown on both statute of limitations and filing deadlines with courts and the IRS.
CAROLINE D. CIRAOLO PARTICIPATED IN THE PANEL “PARALLEL PROCEEDINGS,” AT THE 3RD ANNUAL LIGHTFOOT WHITE COLLAR INSTITUTE
Yoram Keinan moderated the panel "The New Hedging Standard and its Business Drivers" at the Financial Instruments: The Way Forward conference
Business leaders helped the FASB shape the new hedge accounting standard to better align rules with corporate risk management, reflect the economic results of hedging in financial statements, and simplify hedge accounting treatment. This panel highlighted examples of business drivers behind the changes and how companies are faring post-adoption.
- Jon Howard, Audit & Assurance Partner, Deloitte & Touche LLP
- Animesh Jaiswal, Hedge Accounting Derivatives Specialist, Bloomberg LP
- Larry Lu, Director Global Technical Accounting, Walgreens Boots Alliance
Moderator: Yoram Keinan, Partner, Kostelanetz & Fink
Claude M. Millman gave the Keynote Speech "Attorney Misconduct and Rule 8.4(c): Varsity Blues and Other Examples" at the New York Law School 16th Annual Tax Lawyering Workshop
Bryan C. Skarlatos participated in a panel presentation titled “Economic Substance, Judicial Doctrines And Legal Ethics” at PLI's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2019
Impact on partnerships of recent judicial decisions, legislation, and administrative developments relating to economic substance, tax shelters and the codification of the economic substance doctrine, including LB&I Directives; penalty defenses, rules of professional responsibility and conduct, including Circular 230 and related ethical considerations that come into play in evaluating the difference between good tax planning and overly aggressive or even criminal tax advice.