The Inn is an invitation-only professional organization devoted to white-collar practice. Membership in the Edward Bennett Williams American Inn of Court, which has the distinction of being one of only a few Inns of Court focusing on white-collar criminal prosecution and defense, includes D.C. Circuit Court judges, District Court judges and Superior Court judges, U.S. Department of Justice officials and some of the most established defense attorneys in Washington, D.C.
Michael Sardar and Caroline Ciraolo participated in a panel titled "IRS Voluntary Disclosures: Past, Present, And Future" at The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference
The IRS has offered noncompliant taxpayers a path to come into compliance for decades. First, under the Internal Revenue Manual voluntary disclosure practice, and then under the historic Offshore Voluntary Disclosure Programs. In November 2018, the IRS announced new provisions that will apply to all future domestic and offshore voluntary disclosures. Since then, practitioners have been debating the new voluntary disclosure practice and its impact on clients, and taxpayers are wondering if this is the best approach to resolve outstanding issues. The panelists outlined the new framework and engaged in a spirited discussion regarding various open issues and best practices.
Caroline D. Ciraolo presented the CPE/CLE course "What’s New in Federal Tax Enforcement?" at The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference
Caroline Ciraolo, partner with Kostelanetz & Fink, LLP in Washington, D.C. and former Acting Assistant Attorney General of the Tax Division, U.S. Department of Justice, discussed current priorities of the IRS and the Tax Division, domestic and international audit campaigns, current staffing and budget issues, new investigative units, and recent enforcement statistics.
Michael Sardar presented the CPE/CLE course "Working with Schedule C Taxpayers Without Complete Records: Reconstruction, Estimates, and Best Practices" at The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference
In the event of a loss of client records or due to poor record keeping, a paid preparer may need to help his client reconstruct the records and/or make estimates. This session covered tips and ideas on how to handle such issues from tax-return preparation through audit and will include a review of the Schedule C Form, common Schedule C pitfalls, and the best practices for how the tax return preparer and client can utilize estimates and reconstructions in these situations. The session also addressed the Cohan rule and the AICPA Statement on Standards with respect to the use of estimates.
Yoram Keinan moderated a panel titled "Corporate Restructuring In A Cross-Border Context" at the Bloomberg Tax Leadership Forum
This session took a deep dive into international restructuring and discuss the mitigation of tax exposure risks in M&A transactions. We also discussed the role of financial instruments in a cross-border context as well as foreign currency issues.
Michael Sardar moderated a panel titled "Areas of Controversy Under the TCJA" at the NYU SCPS 11th Annual Tax Controversy Forum
The TCJA made sweeping changes to the Internal Revenue Code, and while Treasury and the IRS have done a Herculean job of providing guidance, many of the changes are complex and there is scant legislative history to reveal what Congress intended. Certain provisions of the TCJA will be caught in a cross-current of complexity and ambiguity that may lead some taxpayers to take aggressive reporting positions. This panel identified some of those provisions and the areas in which controversies are likely to ensue.
Caroline D. Ciraolo interviewed Richard E. Zuckerman, Esq. for the "Department of Justice Update" at the NYU SCPS 11th Annual Tax Controversy Forum
Richard E. Zuckerman, Esq., Principal Deputy Assistant Attorney General, Tax Division, US Department of Justice, Washington, DC
Interviewer: Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
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Stephen A. Josey moderated a panel titled "Blurring the Lines: When Is Tax Advice Subject to the Attorney Client Privilege?" at the NYU SCPS 11th Annual Tax Controversy Forum
Tax lawyers often provide clients with advice on how things should be treated on a tax return. Are these communications legal advice or accounting advice? What is the difference between tax advice and return preparation advice? Are there clear rules that provide guidance in these areas? This panel reviewed the way in which courts apply the attorney client privilege to lawyers who give tax advice and explains how you can insure that your communications with your client remain confidential.
Caroline D. Ciraolo moderated a panel titled "How Well Do Your Secrets Travel? Understanding the Scope of Privileges in Crossborder Audits and Investigations" at the NYU SCPS 11th Annual Tax Controversy Forum
International tax enforcement is a top priority of the IRS and the Department of Justice. Audits and investigations routinely involve the collection of information, documents, and testimony outside the United States, leaving tax practitioners to determine what, if any, privilege applies and how those privileges can be preserved in various jurisdictions. This panel of experienced tax controversy attorneys addressed 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 and cross-border audits and investigations.
The NYU School of Professional Studies is pleased to present the 11th Annual Tax Controversy Forum. The Tax Controversy Forum brings together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, and civil and criminal tax penalties.
Enforcement is an essential part of our federal tax system. The Tax Controversy Forum is an opportunity to stay current on new developments, exchange ideas, and share practice tips that can contribute to a better functioning system. Participants qualify for CPE and CLE credits. As a premier educational institution, the NYU School of Professional Studies is committed to providing the highest standard of professional enrichment.