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Megan L. Brackney presented "Exploring The Limits Of The Evolving Economic Substance And Business Purpose Doctrines And Related Penalty And Ethics Issues" at PLI's Tax Strategies for Corporate Acquisitions Program

Guidance on making sure your transactions will pass muster under the Economic Substance, Sham Transaction, Substance over Form and related doctrines; determining when the IRS will respect a transaction as structured and when will it disregard the form of the transaction to disallow the claimed tax benefits.

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Sharon L. McCarthy participated in the panel titled "Jury Selection And Trial In The Social Media Era" at the Pennsylvania Association of Criminal Defense Lawyers 2018 White Collar Practice Seminar

Jurors, lawyers and clients possess an Internet presence to varying degrees. This panel explored emerging case law, existing ethics opinions and the practical realities of lawyers researching Internet and social media postings of potential and actual jurors during jury selection and trial.

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Megan L. Brackney presented "Ethical Issues In Tax Practice" at the 16th Annual Nassau/Suffolk Chapter of NCCPAP/IRS Long Island Tax Professionals Symposium

This program discussed the professional and ethical standards in Circular 230, the AICPA Statements on Standards for Tax Services, and the Internal Revenue Code. We discussed standards for return positions, what to do when you learn about a client’s error or omission, the rules governing practice before the IRS, and other professional ethical issues.

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Caroline Rule presented the CPE/CLE Course: When You May Use & Disclose A Client’s Tax Return Information Under 26 U.S.C § 7216

Under 26 U.S.C. § 7216, it is a crime for a tax return preparer to knowingly or recklessly disclose any tax return information, or use that information other than in tax return preparation. There are also civil penalties under 26 U.S.C. § 6713 for wrongful disclosures or uses of tax return information. The definitions of “tax return preparer” and “tax return information” are so broad, and the governing regulations so complex, that an attorney or accountant may inadvertently or “recklessly” violate section 7216 with no intent to do so. Caroline discussed and simplified section 7216 and its regulations.

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Bryan C. Skarlatos presented "Finding And Defending The Accused" at the 2018 AICPA National Tax Conference

The AICPA’s National Tax Conference, hosted in the heart of the nation’s capital and online, brought leading tax practitioners and key government officials together to present differing and shared positions for a thoughtful review of potential scenarios, tax priorities and a pulse check of the ever-changing tax landscape.

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Michael Sardar Cited in FBAR Decision

In the recent decision in United States v Edward Flume, the court cited a 2010 article on FBAR penalty cases written by Michael Sardar.  The decision in the case to deny summary judgment to collect willful FBAR is part of a recent trend away from ruling for the government in FBAR penalty cases. Michael explored the issue further in a recent article in the Journal of Tax Practice and Procedure.

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Caroline D. Ciraolo presented "IRS Employment Tax Update" at the 2018 Annual Meeting of the California Tax Bar & California Tax Policy Conference

This panel provided a federal employment tax update. The panel discused new administrative, regulatory, legislative developments and case law relevant to employment tax withholding and reporting. 

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Caroline D. Ciraolo presented "The Long War Continues: Considerations In Litigating The FBAR Penalty" at the 2018 Annual Meeting of the California Tax Bar & California Tax Policy Conference

The IRS’ campaign against taxpayers with undisclosed offshore accounts and assets is entering its second decade. One of the principal weapons to enforce compliance is the civil FBAR penalty, which the IRS has been using with increasing frequency. This has resulted in a rising number of civil FBAR cases. 

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Caroline D. Ciraolo presented "It's A Small World - The Use Of Exchange Of Information For Tax Enforcement" at the 55th Annual Hawaii Tax Institute

Practitioners interested in keeping abreast of the latest developments in tax and wealth transfer matters participated in the 55th Annual Hawaii Tax Institute sponsored by the Hawaii Tax Institute Foundation and Chaminade University of Honolulu.

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Michael Sardar presented "Offshore Tax Enforcement - Straight From The Horse’s Mouth & FBAR Strategies For Practitioners After The End Of The Voluntary Disclosure Program" at the AAA-CPA National Convention

The AAA-CPA is an organization comprised of individuals who have dually-qualified as attorneys and certified public accountants. Its mission is to provide its members with quality education, opportunities to connect and the professional resources to support and develop their practices. 

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