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Megan L. Brackney presents "Coming into Compliance Representing Taxpayers with Unreported Foreign Assts," NYU 7th Annual Tax Controversy Institute, NYC, NY

Taxpayers continue to use the Offshore Voluntary Disclosure Program and related programs to report previously undeclared foreign assets. The IRS changed the OVDP in July 2015 to allow certain taxpayers to make streamlined submissions and to pay reduced penalties or to avoid penalties altogether. However, streamlined submissions are available only to taxpayers who can certify that their past non-compliance was not willful. What does willfulness mean in this context and who is eligible to make a streamlined submission? This program discusses which taxpayers must use the OVDP and which taxpayers should consider a streamlined submission, as well as the issues involved in making streamlined submissions.

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Bryan Skarlatos quoted in Wall Street Journal article, "The New Rules of Offshore Accounts"

Many people with offshore issues are considering their options for coming into compliance with U.S. tax rules, given the threat of exposure due to Fatca and the potentially stiff penalties.

But choosing the right way to go about it isn’t easy, and advice is often expensive.

Mr. Hodgen, the Pasadena lawyer, has helped hundreds of U.S. taxpayers with offshore issues. He cautions people with problems not to give into “fear-mongering” by advisers.

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Jerald August presents at the 15th Annual Oregon Tax Institute, “Acquisitions of Privately-Owned Companies by Private Equity Firms”

This year’s Tax Institute offers a faculty of experts covering a wide range of topics, from private equity to choice of entity for entrepreneurs. Examine the final and proposed regulations for the net investment income tax and how to advise clients with non-U.S. assets and financial accounts. Take a look at selected tax issues that concern financially distressed partnerships and tax considerations when negotiating acquisition agreements. Learn how a nonprofit’s Form 990 may be its most important public relations document. Recent federal income tax developments will be discussed, as well as a look at the state and local tax landscape. The ethics session will explore common challenges facing tax attorneys, such as identifying the client and managing clients engaged in questionable conduct. The Taxation Section’s Award of Merit will also be presented during the Tax Institute.

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Michael Sardar Presented "Willfulness: Determining the Correct Path Forward for Taxpayers with Non-Compliant Foreign Assets," at NY Tax Study Group hosted at the Penn Club

On May 18, 2015, Michael Sardar presented "Willfulness: Determining the Correct Path Forward for Taxpayers with Non-Compliant Foreign Assets" at the NY Tax Study Group (NYTSG) hosted at the Penn Club.

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Bryan C. Skarlatos presents at the Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2015 on May 13th, 2015

Bryan C. Skarlatos will be participating in PLI's upcoming Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2015.  This will take place May 12th to May 14th at the new state-of-the-art New York Conference Center.  Mr. Skarlatos will be presenting at 5:00pm on May 13th on Economic Substance, Judicial Doctrines, and Ethics.

 

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Bryan C. Skarlatos presents at the PLI Partnership Program, May 13, 2015, "Economic Substance, Judicial Doctrines and Ethics”

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, 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. 

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Megan L. Brackney presents, "Defending Clients from the Trust Fund Recovery Penalty," American Bar Assocation Section of Taxation, Washington, DC. May 8, 2015

Megan L. Brackney presents, "Defending Clients from the Trust Fund Recovery Penalty," American Bar Assocation Section of Taxation, Washington, DC. May 8, 2015

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Megan Brackney Presents "Defending Clients from the Trust Fund Recovery Penalty" at American Bar Association of Taxation, Washington D.C.

Megan Brackney Presents "Defending Clients from the Trust Fund Recovery Penalty" at American Bar Association of Taxation, Washington D.C.

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Bryan C. Skarlatos presents at Inside Bitcoins, May 13, 2015, "Taxation of Bitcoin”

Bryan C. Skarlatos presents at Inside Bitcoins, May 13, 2015, "Taxation of Bitcoin”

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Bryan C. Skarlatos presents at WeiserMazers Breakfast Seminar on "The Impact of FATCA"

Bryan C. Skarlatos presents at WeiserMazers Breakfast Seminar on "The Impact of FATCA" on April 2, 2015 in New York, NY.

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