Caroline D. Ciraolo and Robert Russell Participated on the Panel "What Every Estate Planner Needs to Know About International Tax and Reporting and the Government's Enforcement and Initiatives" at the 2019 Meeting of the California Tax Bar
Caroline D. Ciraolo and Robert Russell participated on the panel "What Every Estate Planner Needs to Know About International Tax and Reporting, and the Government's Enforcement and Initiatives" at the 2019 Annual Meeting of the California Tax Bar & California Tax Policy Conference in San Diego, CA.
Caroline D. Ciraolo Participated in a Panel Entitled "IRS Voluntary Disclosure Program and Updates on the Other Offshore Procedures" at the 56th Annual Hawaii Tax Institute on November 5, 2019
An analysis of the new and updated IRS voluntary disclosure program which covers
domestic and foreign cases. Also included will be an update of the other offshore
procedures (Streamlined Domestic Offshore Procedures, Delinquent Procedures
for FBARs, and International Forms); hands on practical advise on how the IRS
administers these programs; and how to get your clients through the process.
Caroline D. Ciraolo Participated in the Panel Entitled "Caution Trustees - Beware of Unresolved Tax Liabilities of Incapacitated Taxpayers and Decedents; Ethical Considerations" at the Hawaii Tax Institute on November 4, 2019
Fiduciaries need to be aware of the potential for personal liability if distributions
are made to beneficiaries prior to fully satisfying tax liabilities of an incapacitated
taxpayer or decedent. Under 37 USC section 3713, known as the “Federal Priority
Act,” a fiduciary may be held personally liable for any distribution in contravention of the Federal Priority Act if the incapacitated or deceased taxpayer (i) failed
to file any tax return, (ii) failed to pay any tax, interest or penalties, or (iii) filed
inaccurate or incomplete tax returns. This session will discuss the Federal Priority
Act, actions that the fiduciary may consider taking to minimize its application, how
probate courts address these issues, ethical considerations, and what efforts can
be made to enable the fiduciary to receive a full release of personal liability.
Caroline D. Ciraolo Participated as a Keynote Speaker in the Seminar "Paying U.S. Taxes in Canada: Are you caught on the borderline?" on November 2, 2019
Are you a U.S. Citizen, Green Card holder, born on U.S. soil or born abroad to a U.S. parent and live in Canada? Do you have financial accounts in Canada or anywhere outside of the U.S.? If you have never filed U.S. tax returns or are behind on annual tax filings or reporting financial accounts, you could be subject to significant penalties up to $10,000 (USD) per account, per year unreported.
NEW YORK (November 1, 2019) — Kostelanetz & Fink, LLP, has been recognized as a Tier 1 National “Best Law Firm” in three categories, Tax Law, Criminal Defense: White-Collar, and Litigation – Tax by U.S. News – Best Lawyers® for 2020.
Tax Controversy Corner: Can Taxpayers Rely on Informal Guidance in Attempting to Comply with the TCJA?
By Megan L. Brackney
Journal of Passthrough Entities
September - October 2019 Edition
As Treasury and the IRS implement the Tax Cuts and Jobs Act (“TCJA”) of 2017, it is a good time to consider when taxpayers can rely on informal IRS guidance, such as publications, forms, instructions, and frequently asked questions (“FAQs”) on the IRS’s website. The TCJA is one of the most significant overhauls of the Code in decades, and the interpretation and implementation of many of its provisions are unclear. The IRS has published numerous resources to assist taxpayers with compliance with the new and amended Code provisions, and many taxpayers and practitioners will rely on these unofficial sources while they wait for official guidance, such as Treasury Regulations and Revenue Procedures. It seems intuitive that if you follow the instructions provided by the IRS, you will get the correct tax result, but this is not always the case. It also seems intuitive that if you follow the instructions by the IRS and still get it wrong, you should not be subject to penalties. Taxpayers may be surprised to learn that these results are far from guaranteed, but, as stated by several courts, taxpayers rely on the IRS “at their peril.”
Over the past few months, Kostelanetz & Fink, LLP, has been expanding, as our Washington, D.C., office continues to grow and our bench of professionals in both New York and D.C. gets deeper. At the same time, we’ve been gratified that a number of our paralegals were accepted to law schools at some of the country’s top universities, while we added new paralegals from some of those same universities. A few of the recent highlights of these welcome developments include:
Caroline D. Ciraolo Presented "Recruiting and Retaining Women in Tax – What Does it Take?" to the Tax Section of the Federal Bar Association in Washington, D.C. on October 25, 2019
Usman Mohammad participated as a speaker in the webinar entitled “FATCA After Tax Reform: Form 8938 Reporting for Taxpayers With Foreign Assets, Integrating Latest IRS Guidance,” on October 24, 2019
Usman Mohammad participated in a Strafford webinar which provided tax advisers with a practical guide to the Foreign Account Tax Compliance Act (FATCA) reporting for taxpayers holding foreign assets. The panel defined reportable "specified foreign assets," discussed valuation issues, and offered thorough instruction on completing Form 8938, Statement of Specified Foreign Assets. The webinar outlined how the 2017 tax reform law and subsequent IRS guidance changed the thresholds for reporting requirements.