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.
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.
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.
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.
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.
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.
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.
Caroline D. Ciraolo presented "Summer Of Norman, Wahdan, Colliot: Defending Title 31 FBAR Penalties: Pre And Post-Assessment, IRS & DOJ Policies And Strategy" at the 14th Annual USD Procopio International Tax Institute
Ms. Caroline D. Ciraolo, Esq., Partner - Kostelanetz & Fink (Former Acting Assistant Attorney General of the U.S. Department of Justice's Tax Division)
NEW YORK (November 1, 2018) — Kostelanetz & Fink, LLP, has been named a Tier 1 National “Best Law Firm” for both Tax Law and Litigation – Tax by U.S. News – Best Lawyers® in 2019.
Michael Sardar presented "Privilege: Trending Topics And A Practical Guide For The In-House Tax Counsel" at the Life Insurance Council of New York (LICONY) 34th Annual Conference
Mr. Sardar shared his extensive knowledge with those in attendance.