Caroline Ciraolo made substantive contributions to the American Bar Association Taxation Section Comments on the proposed changes to Tax Court Rule 24. The comments were formally submitted to Chief Judge Foley of the U.S. Tax Court on June 1, 2020.
Caroline Ciraolo was interviewed for the American Citizens Abroad (ACA) TaxCast podcast. Part 1 of her interview was posted May 15, 2020, and Part 2 was posted on May 31, 2020. During Part 2 of the program, Ms. Ciraolo takes a "deeper dive" into the types of tax professionals and government officials that may play a role in a client’s tax matters, the nature and risks of an “eggshell” audit, the scope of applicable privileges, best practices for vetting clients and managing an examination or investigation, and much more.
Robert M. Russell quoted in Bloomberg Tax article entitled "IRS Fixes to Foreign Tax Credit Rules Could Boost New Virus Perk"
In a recent Bloomberg Tax article by Siri Bulusu entitled "IRS Fixes to Foreign Tax Credit Rules Could Boost New Virus Perk," Robert M. Russell discussed how benefits, such as a net operating loss carry back provision, restored in response to the COVID-19 crisis could affect and interact with prior deductions and perks.
Megan Brackney presented a webinar entitled "IRS Summons and Other Methods of Obtaining Taxpayer Information, Enforcement, and Defenses" for Celesq Attorneys Ed Center, on May 21, 2020
The IRS has several methods for obtaining information about taxpayers. This program discussed the IRS’s methods of obtaining information, focusing primarily on the IRS’s summons authority, including the scope of that authority, taxpayer’s rights and privileges, summons enforcement litigation, and the attorney’s ethical obligations when responding to IRS requests for information under Circular 230.
Paul Butler quoted in Tax Notes article entitled "Work-From-Home Technology Comes With New Privilege Concerns"
In a recent Tax Notes article by Nathan J. Richman entitled “Work-From-Home Technology Comes With New Privilege Concerns," Paul Butler discussed concerns about how to safeguard attorney-client privilege and protect the work product doctrine when using videoconferencing and other new technological tools that tax professionals are relying on during the coronavirus pandemic.
Caroline Ciraolo quoted in two-part Tax Notes series regarding new IRS guidelines for voluntary disclosure
On May 13 and 14, 2020, Caroline Ciraolo sat down with Tax Notes to discuss the revised Form 14457 and new guidance on the IRS voluntary disclosure practice in a two-part series.
Caroline Ciraolo was interviewed for the American Citizens Abroad (ACA) TaxCast podcast. Part 1 of her interview was posted May 15, 2020, and Part 2 is due to post on May 31, 2020. During Part 1 of the program, Ms. Ciraolo discussed non-filers and the CARES Act stimulus payments, voluntary disclosure, streamlined filing compliance procedures, delinquent international information return submission procedures, and other compliance-related matters.
Bryan C. Skarlatos participated in a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know" at the Tax Planning for Partnerships 2020 web conference for PLI on May 14, 2020
Bryan C. Skarlatos and Bradley M. Seltzer reviewed the ethical rules related to advising clients on transactions involving partnerships and other passthrough entities, using a real-life hypothetical, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit; ethical rules covered include standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Paul T. Butler participated in a webinar entitled “Practical Privilege Issues in Income Tax Disputes" for the ABA Tax Section , on May 14, 2020
This panel discussed the rules protecting communications from disclosure, including attorney-client, work product, and I.R.C. section 7525 privileges. The panelists demonstrated application of those privileges using real-world examples, touching on hot topics, and providing best practices to use in disputes with taxing authorities.
Megan Brackney presented a webinar entitled "Form 8300 Reporting Requirements and Penalties" for the CPA Academy, on May 13, 2020
This program discussed the requirements to file Forms 8300 to report cash transactions in a trade or business of over $10,000 and to furnish annual statements to customers. Ms. Brackney outlined the basics of Form 8300 compliance, and then went into further discussion about the potential penalties, defenses to penalties, and the methods of challenging Form 8300 penalties.