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Caroline D. Ciraolo co-chaired and moderated "Identifying The Line Between Avoidance And Evasion: Global Criminal Tax Enforcement" at the 19th Annual U.S. and Europe Tax Practice Trends Conference

Whistleblowers, data leaks, and cooperators have brought allegations of criminal tax violations the forefront and countries around the world are facing increased pressure to take aggressive action, hold those involved accountable, and recover lost revenue. 

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BRYAN C. SKARLATOS QUOTED IN "The $26 Million Question: What Happens if You Don’t File Your Taxes for a Decade?", THE WALL STREET JOURNAL

The IRS can fill out a substitute return for you—and it usually isn’t accurate. And a lot of penalties and interest will accrue.

Even if you don’t go to jail, blowing off the Internal Revenue Service is a really bad idea.

Take Larry Cecil Cabelka of Megargel, Texas. Mr. Cabelka didn’t submit tax returns for 12 years during the 1990s and 2000s, according to a March 26 ruling by a U.S. appeals court. As a result, said the court, he owes the U.S. more than $26 million.

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Paul Butler participated in a panel titled “Connecting The Dots – Managing Privilege In An Interconnected World” at the Tax Executives Institute

The contours of various privileges (attorney-client, attorney work product, spousal, etc.) vary from one jurisdiction to another domestically from whether each privilege exists to who holds (or “owns”) the privilege to how it is waived or preserved. Putting those issues into cross-border transactions and negotiations conducted through a variety of communication vehicles only increases the complexities, some of which were identified and unraveled in this panel discussion.

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Yoram Keinan presented "Taxation Of Financial Products And Institutions In The Aftermath Of TCJA" at the Tax Executives Institute

March 31 - April 3, 2019 - Grand Hyatt Hotel, Washington, D.C. 
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Avoiding Litigation When Auditing Government Contractors

By: Claude M. Millman
The CPA Journal
April 2019 Edition

Government contracting is big business. More than 4 million contractors serve the U.S. government, and they collectively receive more than $500 billion per year. While many people think of those federal contracts when they refer to “government contracts,” states and municipalities also have substantial contracting budgets. For example, New York City (where the author used to serve as chief procurement officer) spends close to $20 billion per year through roughly 40,000 procurement actions.

Of course, government contractors need tax preparation and auditing services. While CPAs can be of great service to such clients, government contracting involves special risks that can affect contractors and the accountants they retain. Before agreeing to audit a government contractor, it is useful to consider these issues, recognize how they may lead to controversies and litigation, and take steps to mitigate the chances that small problems will become big ones.

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IRS Issues New Guidance For Offshore Voluntary Disclosures

By: Michael Sardar
Tax Stringer
April 2019 Edition

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On March 13, 2018, the IRS announced that it would end its long-running Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. With the closure of one of the IRS’s most successful compliance enforcement programs, practitioners were anxious for the IRS to announce a new program to take its place. On November 20, 2018, the IRS issued a memorandum titled “Updated Voluntary Disclosure Practice,” which announced new guidance for the way the IRS would process new voluntary disclosure applications made after the closure of the OVDP.

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The People Of The State Of New York Vs. M. Robert Neulander - Brief For Amicus Curiae In Support Of Defendant-Respondent

Caroline Rule, as Counsel to the New York Council of Defense Lawyers, authored an Amicus Curiae brief in the New York Court of Appeals in regards to the case People v. Neulander in which the prosecution is appealing the Appellate Division, Fourth Department’s grant of a new trial to Mr. Neulander on the grounds of juror misconduct.  The Amicus brief urges the Court of Appeals to affirm the Appellate Division’s decision, based both on New York law and on decisions from other jurisdictions around the country.

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Caroline D. Ciraolo participated in the panel titled "What Every Estate Planner Needs To Know About International Tax And Reporting, And The Government’s Enforcement And Initiatives?" at the CLA Tax Section Annual Estate and Gift Tax Conference

CLA Tax Section Annual Estate and Gift Tax Conference



Caroline D. Ciraolo participated in the panel titled "Updated Voluntary Disclosure Procedures: Is This The Correct Path For Your Noncompliant Client?" at the 43rd Annual Tax Law Conference

2019 promises to be a key year for the tax bar. With landmark administrative guidance in the wake of tax reform, practitioners will be contending with fast-paced developments that will have immediate and immense effects. 

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Jay Nanavati participated in the panel titled "Technology in Tax Enforcement" at the 43rd Annual Tax Law Conference

Attendees learned about the role of “big data” in the IRS’s and DOJ’s efforts to efficiently analyze the vast amounts of data that it receives from FATCA, the former Offshore Voluntary Disclosure Program, the current Voluntary Disclosure Practice, the Swiss Bank Program, and Suspicious Activity Reports.

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