Caroline Rule Article on U.S. v Greenfield Selected for Inclusion in the March/April Magazine of the ABA General Practice Division
Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2), has been selected for inclusion in the March/April magazine of the ABA General Practice Division, which will focus on “The Best of ABA Sections”--a compilation of some of the best articles published by the ABA’s sections, forums, and divisions.
In his more than two decades of experience in both the U.S. and Israel, Yoram Keinan has developed extensive experience with respect to the domestic and international taxation of financial products and institutions, and he’s been bringing that knowledge to classrooms at both his alma mater, the University of Michigan Law School, and Georgetown Law Center in a class that is again being offered at both schools, “Taxation of Financial Instruments and Transactions.”
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), which includes tax provisions intended to provide an economic stimulus to both businesses and individuals. The stated policy of the new legislation is to increase cash flow and liquidity and to reduce the cost of capital.
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.
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.
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).
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.”
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.”
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.
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.