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.
Bryan C. Skarlatos chaired the panel "Crossing The Line: Real Life Ethical Issues In Tax Practice" at the NYU-SPS 77th Institute on Federal Taxation
Mr. Skarlatos also presented this panel on November 15 in San Diego, CA.
Tax practice can be categorized into three different stages: tax planning, tax return preparation and audit/trial representation. Each stage has its own ethical considerations. This panel discussed the ethical issues that arise at each stage of the process.
Megan L. Brackney participated in the panel titled "Ethics: Challenges For The Tax Professional Advising Clients Looking To Push The Envelope" at the NYU-SPS 77th Institute on Federal Taxation
Tax practitioners are frequently asked by their clients to provide them with guidance and authority on difficult legal issues. This panel discussed the different techniques for providing clients with legal guidance when the law might not be clear.