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.
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.
Christopher M. Ferguson moderated a panel titled "Following the Money: The Ins and Outs of Construction Industry Audits and Investigations" at the NYU SCPS 11th Annual Tax Controversy Forum
Construction projects often involve large amounts of money changing hands among a large number of people creating a situation that is ripe for mistakes and even fraud. In response, the government has developed investigative technics specifically for uncovering tax non-compliance in the construction industry. This panel reviewed how the government approaches audits and investigations in the construction industry and practical tips for representing taxpayers who are faced with having to explain where their money came from and where it went.
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.
Brian Ketcham participated in a panel titled "International Information Return Litigation" at the Agostino & Associates Tax Controversy Update
Caroline D. Ciraolo and Michael Sardar Participated In A Panel Titled "FBAR & FATCA: The Crackdown On Unreported Foreign Assets Continues" at The AICPA ENGAGE 2019 Conference
U.S. taxpayers and residents are required under the Internal Revenue Code and the Bank Secrecy Act to report their relationship to foreign accounts and assets on an annual basis. The IRS and the Department of Justice have significantly increased enforcement of these reporting requirements through criminal prosecutions and the imposition of crushing civil penalties that can come when taxpayers are not compliant. This panel explored the current state of IRS and DOJ civil and criminal enforcement with respect to taxpayers who have not complied with FBAR (Report of Foreign Bank and Financial Accounts) and FATCA (Foreign Account Tax Compliance Act) reporting requirements. The panel also covered pathways to compliance for the non-compliant taxpayer, including the IRS’s Voluntary Disclosure Practice.
CAROLINE D. CIRAOLO AND BRYAN C. SKARLATOS PARTICIPATED IN A PANEL ON "IRS CONTROVERSIES" AT THE AICPA ENGAGE 2019 CONFERENCE
As IRS enforcement becomes more automated, the need for trained representatives who know what to do and when to do it has never been greater. This panel covered the mechanics of representing taxpayers before the IRS, including exam and collections, so that attendees can identify and understand when taxpayers need help, and how to go about the process of helping them resolve their IRS issue.
1) Explain the process for challenging an exam issue with the IRS
2) Understand the IRS collection process
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Caroline D. Ciraolo and Bryan C. Skarlatos participated in a panel on "IRS Exams and Appeals" in the IRS Workshop at the AICPA ENGAGE 2019 Conference
As IRS enforcement becomes more automated, the need for trained representatives who know what to do and when to do it has never been greater. This panel covered the mechanics of representing taxpayers before the IRS, including Exam, Appeals and Collections, so that attendees could identify and understand when taxpayers need help, and how to go about the process of helping them resolve their IRS issue. This session was covered in 2 parts: 1:00 - 3:00 pm: Part 1 - Examinations and Appeals (Bryan Skarlatos and Caroline Ciraolo) 3:00 - 5:00 pm: Part 2 - IRS Collections (Eric Green, Robert McKenzie and Paul Mamo, IRS Director of Collections).
1. Understand the examination process
2. Identify opportunities to challenge an examiners findings
3. Explain the process for appealing from an IRS examination
4. Understand the IRS collection process
5. Explain the options taxpayers have to resolve an outstanding tax debt
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