Yoram Keinan and Stow Lovejoy participated in the panel titled "The Current State of the Economic Substance Doctrine and its Effect on Financial Institutions" at the ABA Section of Taxation, May Tax Meeting
The economic substance doctrine was “codified” in 2010, effective for transactions after March 31, 2010, and a new strict liability penalty added for economic substance understatements. While the IRS and Treasury provided initial guidance on the application of the codified doctrine and the penalty, only a handful of cases have considered post-codification transactions. This panel discussed how the economic substance doctrine has developed since codification and the extent to which the doctrine and the penalty should concern financial institutions in planning and examinations.
Michael Sardar participated in the panel "Asset Protection And Offshore Assets: Hide And Seek In The World Of Divorce" at the AAML/BVR National Divorce Conference
Brought to you by the American Academy of Matrimonial Lawyers (AAML) and Business Valuation Resources (BVR), the National Divorce Conference brought together the leading matrimonial attorneys and financial experts for the only event of its kind.
Paul Butler participated in the panel titled "Statutes of Limitations in Tax Litigation: Friend or Foe?" at the ABA Section of Taxation, May Tax Meeting
Statutes of limitations are an important, but often overlooked, aspect of tax litigation that can work to the advantage or the detriment of a party. Most practitioners are familiar with the general three-year period of limitation on assessment, as well as basic exceptions, including those for a false return, no return, or a substantial omission of gross income. This panel addressed more nuanced rules affecting statutes of limitations in tax, including the interplay of section 6511(a) and (b) in refund suits (and, as appropriate, Tax Court litigation), the failure to notify the IRS of certain foreign transfers, and the failure to disclose listed transactions. The panelists also discussed strategies for navigating statute of limitation issues in litigation, as well as the effect of the government shutdown on both statute of limitations and filing deadlines with courts and the IRS.
CAROLINE D. CIRAOLO PARTICIPATED IN THE PANEL “PARALLEL PROCEEDINGS,” AT THE 3RD ANNUAL LIGHTFOOT WHITE COLLAR INSTITUTE
Yoram Keinan moderated the panel "The New Hedging Standard and its Business Drivers" at the Financial Instruments: The Way Forward conference
Business leaders helped the FASB shape the new hedge accounting standard to better align rules with corporate risk management, reflect the economic results of hedging in financial statements, and simplify hedge accounting treatment. This panel highlighted examples of business drivers behind the changes and how companies are faring post-adoption.
- Jon Howard, Audit & Assurance Partner, Deloitte & Touche LLP
- Animesh Jaiswal, Hedge Accounting Derivatives Specialist, Bloomberg LP
- Larry Lu, Director Global Technical Accounting, Walgreens Boots Alliance
Moderator: Yoram Keinan, Partner, Kostelanetz & Fink
Claude M. Millman gave the Keynote Speech "Attorney Misconduct and Rule 8.4(c): Varsity Blues and Other Examples" at the New York Law School 16th Annual Tax Lawyering Workshop
Bryan C. Skarlatos participated in a panel presentation titled “Economic Substance, Judicial Doctrines And Legal Ethics” at PLI's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2019
Impact on partnerships of recent judicial decisions, legislation, and administrative developments relating to economic substance, tax shelters and the codification of the economic substance doctrine, including LB&I Directives; penalty defenses, rules of professional responsibility and conduct, including Circular 230 and related ethical considerations that come into play in evaluating the difference between good tax planning and overly aggressive or even criminal tax advice.
CAROLINE D. CIRAOLO PRESENTED “BUSINESS OR PLEASURE? NAVIGATING THE INTERNAL REVENUE CODE WHEN YOUR BOAT IS A BUSINESS,” AT THE RECREATIONAL BOATING COMMITTEE MEETING OF THE MARITIME LAW ASSOCIATION OF THE UNITED STATES
Chambers USA Recognizes K&F and its Attorneys as Leaders in Tax Controversy and White-Collar Defense
“An Extraordinary Group of Lawyers Who Are Outstanding Individually and Outstanding as a Team”
NEW YORK, NY (April 30, 2019) – Kostelanetz & Fink is pleased to announce that Chambers and Partners has recognized the firm in its 2019 USA Guide. The guide, released April 25, 2019, recognizes K&F and its attorneys in the areas of tax controversy, tax fraud, tax law, and white-collar defense and government investigations. Chambers USA ranks the top lawyers and law firms across all the United States of America through assessment of a firm’s work and opinions from external market sources, with an emphasis on client feedback.
Caroline D. Ciraolo participated in the webinar titled "Tax Advice In The Age Of The 24-Hour News Cycle" at the ABA Taxation Section
Recent instances of exposure by the press of aggressive tax planning and tax avoidance by prominent businesses, individuals or families raise unique substantive, ethical, and other legal issues for the tax community. Practitioners advising famous clients may need to assess not only the likelihood of future examinations, but also public disclosure due to whistleblowers, cooperators, and data leaks.