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Jerald David August Presented at the American Law Institute CLE Video Webcast Event, “3.8% - What the New Medicare Tax Means for Business Entities and Business Owners"

On Tuesday, December 18, 2012, Jerald David August presented at the American Law Institute CLE Webcast Event, "3.8% - What the New Medicare Tax Means for Business Entities and Business Owners"

Starting on January 1, 2013, the 2010 Health Care Act will subject investment income to the Medicare tax for the first time in the history of Social Security. Under the new Medicare Contribution tax – partners, LLC members, and S-corporation shareholders will be exposed to a 3.8% tax on net investment income attributable to their share of operating income if the activity generating the income is “passive” under Section 469 with respect to the taxpayer.

 

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Jerald David August Presented at the American Law Institute CLE Video Wwebcast Event, “Denying Private Investor Certified Historic Tax Credits: Third Circuit Court of Appeals Reverses Tax Court in Historic Boardwalk Hall"

On Thursday, November 15, 2012, Jerald David August presented at the American Law Institute CLE Webcast Event, "Denying Private Investor Certified Historic Tax Credits:Third Circuit Court of Appeals Reverses Tax Court in Historic Boardwalk Hall"

The Third Circuit's reversal of the fully reviewed Tax Court opinion in Historic Boardwalk Hall, LLC, v. Commissioner of Internal Revenue places concern on how to effectively advise clients on their ability to successfully receive allocations of rehabilitative tax credits, as well as low income housing and other tax credits, which transactions use the partnership form for federal income tax purposes.

The Third Circuit's adverse holding in denying the private investor is based on application of the Culbertson test for determining whether an investor is a "true partner" in a partnership and further includes consideration of various judicial doctrines of economic substance, substance over form, business purpose, and the sham transaction doctrines. The partnership anti-abuse regulations are also relevant.

 

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Jerald David August Presented at the American Law Institute CLE Video Webcast Event, “Attorney-Client Privilege and Work Product Doctrine in Tax Controversies"

On Wednesday, October 31, 2012, Jerald David August presented at the American Law Institute CLE Webcast Event, "Attorney-Client Privilege and Work Product Doctrine in Tax Controversies"

In a civil or criminal tax investigation, legal counsel for the taxpayer must be aware of what information and documents must be produced, or what oral testimony may be demanded,  upon the receipt of an administrative or court subpoena. Frequently, information that is very relevant may also be highly prejudicial to the client’s interest.

 

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Bryan C. Skarlatos quoted in WSJ, October 26, 2012, "IRS Pays $38 Million in Whistleblower Case"

Bryan C. Skarlatos quoted in WSJ, October 26, 2012, "IRS Pays $38 Million in Whistleblower Case"

Bryan C. Skarlatos quoted in WSJ, October 26, 2012, "IRS Pays $38 Million in Whistleblower Case"

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Claude M. Millman quoted in NY Daily News, September 25, 2012 "Center's Lost in City Switch"

Claude M. Millman quoted in NY Daily News, September 25, 2012 "Center's Lost in City Switch"

Claude M. Millman quoted in NY Daily News, September 25, 2012 "Center's Lost in City Switch"

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Jerald David August Presented at the American Law Institute CLE Video Webcast Event, “Recent Developments in Off-Shore Tax Compliance, Including Criminal Tax Investigations"

On Wednesday, September 19, 2012, Jerald David August presented at the American Law Institute CLE Webcast Event, "Recent Developments in Off-Shore Tax Compliance, Including Criminal Tax Investigations"

Compliance with off-shore tax laws has always been complex. In recent years, however, criminal tax investigations have added to this complexity, raising the possibility that lawyers-and their legal fees-may be vulnerable. This all-new video webcast will explore the intricacies of off-shore tax compliance for lawyers and accountants who have clients with interests in foreign bank accounts or other foreign-based entities. It will also be useful to estate planners and business lawyers whose clients reside in multiple jurisdictions or otherwise have investments both within and outside of the United States.

 

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Bryan C. Skarlatos quoted in Reuters, September 11, 2012 "Whistleblower in UBS tax case gets record $104 million"

Bryan C. Skarlatos quoted in Reuters, September 11, 2012 "Whistleblower in UBS tax case gets record $104 million"

Bryan C. Skarlatos quoted in Reuters, September 11, 2012 "Whistleblower in UBS tax case gets record $104 million"

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Kostelanetz & Fink announces that Christopher C. Ferguson, Usman Mohammad, and Joseph Septimus have been elevated to the position of Of Counsel with the firm.

It is with pleasure and pride that Kostelanetz & Fink announces that Christopher C. Ferguson, Usman Mohammad, and Joseph Septimus have been elevated to the position of Of Counsel with the firm.  We all congratulate you.

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Caroline Rule quoted in Reuters "Ex-Mobil Executive Loses Offshore Tax Fight with IRS"

Caroline Rule quoted in Reuters "Ex-Mobil Executive Loses Offshore Tax Fight with IRS"

Caroline Rule quoted in Reuters "Ex-Mobil Executive Loses Offshore Tax Fight with IRS"

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Bryan C. Skarlatos quoted in WSJ, July 10, 2012, "Why Denise Rich Gave Up U.S. Citizenship"

Bryan C. Skarlatos quoted in WSJ, July 10, 2012, "Why Denise Rich Gave Up U.S. Citizenship"

Bryan C. Skarlatos quoted in WSJ, July 10, 2012, "Why Denise Rich Gave Up U.S. Citizenship"

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