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Michael Sardar Led a Webinar Entitled "Working with Schedule C Taxpayers with Incomplete Records," for the CPA Academy, on March 26, 2020

In the event of a loss of client records or due to poor record keeping, a tax preparer may need to help his client reconstruct the records and/or make estimates. 

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IRS Issues FAQs & Updated Guidance on Extension of April 15 Tax Deadlines Due to Novel Coronavirus (COVID-19)

On March 20, 2020, the IRS issued Notice 2020-18, which provides updated guidance on the extension of the April 15, 2020 tax return filing and payment deadlines due to the Coronavirus pandemic. On March 24, 2020, the IRS issued FAQs to answer various questions regarding Notice 2020-18. 

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New IRS Guidance Regarding Certain Tax-Favored Foreign Trusts

In new IRS guidance, certain foreign trusts receive a significant break from information reporting and the potential refund of penalties.

The IRS will now exempt eligible U.S. persons from reporting transactions with, or ownership of, certain tax-favored foreign trusts that are operated exclusively (or nearly exclusively) to provide pension, retirement, medical, disability, or education benefits. Such foreign trusts are likely to include programs such as Canadian registered educational savings plans and registered disability savings plans (RESPs and RDSPs); and UK self-invested personal pensions (SIPPs).

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Megan L. Brackney Quoted in TaxNotes Article Entitled, “Practitioners Fault Accelerated Assessable Penalty Collection”

In a TaxNotes article entitled, “Practitioners Fault Accelerated Assessable Penalty Collection,” Megan Brackney is quoted on how “the IRS’s collections practice for assessable penalties related to foreign information returns is increasingly placing taxpayers in a bind, and practitioners are eager to provide suggestions on how the process can be improved.”

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Claude M. Millman has been recognized by City & State NY at the Law Power 100 Reception for his election to the 2020 Law Power 100 list

City and State notes the list represents “New York’s 100 most influential lawyers . . . based on their achievements, track record and sway in political and policy matters.” The list describes Mr. Millman as a “seasoned attorney who appears regularly on lists of top lawyers” who “focuses on commercial civil litigation” and “has also represented contractors, including nonprofits, doing business with New York City and state.”

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Robert Russell participated in the panel entitled "Outbound Tax Developments," at the Federal Bar Association's 2020 Tax Law Conference

The TCJA made significant changes to how income of controlled foreign corporations is taxed. The operation of the new Global Intangible Low-Taxed Income (GILTI) continues to be molded as guidance is released related to foreign tax credits, previously taxed earnings and profits and foreign-derived intangible income.

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Michael Sardar participated in the panel entitled "When A Civil Audit Turns: Navigating An Audit When The Mistakes Are Not So Unintentional," at the Federal Bar Association's 2020 Tax Law Conference

Tax practitioners, even those who operate primarily in the civil space, should understand the procedures of criminal investigations and the warning signs (both from the client and the government) that a criminal referral is looming. This panel discussed issues that have the potential to influence an I.R.S. examiner’s decision to refer an audit for criminal investigation and offered practitioners tips to navigate those issues, either to avoid referral or to manage the process after a case turns criminal. This panel offered useful insights from both the civil and the criminal tax practitioner perspective.

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Caroline D. Ciraolo participated in the panel entitled "Ethics, Data Breaches, and More," at the Federal Bar Association's 2020 Tax Law Conference

This panel touched on a variety of ethics issues including those arising from limited representation of a client, from service as a personal representative under unified partnership audit procedures, and from a data breach.

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Megan Brackney Named One of Lawline’s “Top Women Faculty of 2019”

Megan Brackney was named by Lawline as one of the “Top Women Faculty of 2019” for a CLE program she taught entitled “Tax Procedure: IRS Methods of Obtaining Information From and About Taxpayers.” Lawline noted that the program “has received 500 views and counting since the December 2019 live broadcast.”

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Caroline D. Ciraolo moderated and Brian P. Ketcham participated in the panel entitled "Criminal Tax Sentencing - Best Practices," at the Federal Bar Association's 2020 Tax Law Conference

The panel reviewed the latest sentencing statistics in criminal tax prosecutions and discussed best practices in connection with negotiating the plea agreement, calculation of tax loss, impact of forfeiture, dealing with Office of Probation and Pretrial Services, character letters, payment of restitution, sentencing memoranda, allocutions, witnesses, conditions of probation or supervised release, and designations.

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