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PAUL BUTLER PARTICIPATED IN THE PANEL TITLED "PRACTICAL PRIVILEGE - USES AND MISUSES IN AN INTERCONNECTED WORLD" AT THE TAX EXECUTIVES INSTITUTE AUDIT AND APPEALS SEMINAR

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Michael Sardar quoted in "Data Analytics Are Coming to an IRS Special Agent Near You", TaxNotes Today

Ever since CI started talking about its new data analytics strategy, the division has been fielding privacy and disclosure concerns.

Asked if the IRS has the right to apply its new sophisticated data analytics tools to a taxpayer’s data, Michael Sardar of Kostelanetz & Fink LLP said that the standard search and seizure analyses involve situations in which the government needs to spend a large amount of resources — for example, with visual surveillance or telephone wiretapping. “There’s a parallel in terms of how much effort the government has to put in versus what they are going to get out of it, and that’s how you determine
what is reasonable,” he said.

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Sharon L. McCarthy participated in a panel presentation titled "The Life-Cycle Of A Criminal Tax Case" at the 3rd Annual Criminal Tax Day

This panel walked attendees through the entire life cycle of a criminal tax case: from referral to CI through investigation, Department of Justice Referral, Indictment, Plea and Sentencing. Whether you have worked 10 criminal tax cases before or never been involved in any, our panel brought attendees up to speed with an explanation and exhibits.

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Jay R. Nanavati participated in a panel presentation titled "A World of Lies: The Truth Behind the Tax Protestor Arguments" at the 3rd Annual Criminal Tax Day

For decades lies and mistruths have been advanced by individuals and groups unhappy with the United States Income Tax.  These individuals and groups often twist facts into more suitable positions to advance their agenda.  Many of these fabrications were reviewed and dissected in the recent United States Tax Court Decision in Waltner vs. Commissioner.  Our esteemed panel reviewed the case and enlightened the attendees to the truth and fiction of the arguments put forth by “tax protestors.”

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Jay R. Nanavati participated in a panel presentation titled "The Interplay Between IRS and State Criminal Tax Investigations" at the 3rd Annual Criminal Tax Day

More frequently than ever, when targets of a criminal tax investigation open their door they will be confronted by three government agents: two from the IRS’s Criminal Investigation Division and one special-agent from the State Department of Revenue Services. This panel discussed the interplay between state and federal tax crimes, and what role the state tax crimes will play in the upcoming investigation and prosecution.

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MICHAEL SARDAR PARTICIPATED IN A PANEL PRESENTATION TITLED "WHAT’S NEW IN CRIMINAL TAX" AT THE 3RD ANNUAL CRIMINAL TAX DAY

A panel of experts updated attendees on the latest priorities and trends in IRS criminal Enforcement, including cyber-crimes, crypto-currency, marijuana, payroll tax crimes, money laundering and good-old-fashioned income tax evasion.

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Moderator: Lisa E. Perkins, Green & Sklarz LLC, West Hartford, CT

Panelists:

  • Kristina O’Connell, Special-Agent In-Charge, IRS Criminal Investigation, Boston Field Office
  • Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ
  • Michael Sardar, Esq., Kostelanetz & Fink, LLP, Washington, DC
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Caroline D. Ciraolo participated in a panel titled "Current Issues in Government Investigations" at the Federal Bar Association

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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.

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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.

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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.            

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