The NYU School of Professional Studies is pleased to present the 11th Annual Tax Controversy Forum. The Tax Controversy Forum brings together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, and civil and criminal tax penalties.
Enforcement is an essential part of our federal tax system. The Tax Controversy Forum is an opportunity to stay current on new developments, exchange ideas, and share practice tips that can contribute to a better functioning system. Participants qualify for CPE and CLE credits. As a premier educational institution, the NYU School of Professional Studies is committed to providing the highest standard of professional enrichment.
CAROLINE D. CIRAOLO AND BRYAN C. SKARLATOS PARTICIPATED IN A PANEL ON "IRS CONTROVERSIES" AT THE AICPA ENGAGE 2019 CONFERENCE
As IRS enforcement becomes more automated, the need for trained representatives who know what to do and when to do it has never been greater. This panel covered the mechanics of representing taxpayers before the IRS, including exam and collections, so that attendees can identify and understand when taxpayers need help, and how to go about the process of helping them resolve their IRS issue.
1) Explain the process for challenging an exam issue with the IRS
2) Understand the IRS collection process
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A continuing decline in Internal Revenue Service audit rates could soon reverse course due to an influx of workers to conduct examinations and a plan to modernize technology at the agency.
The IRS Data Book released in May showed the audit rate for the largest corporations fell to just under 50% in 2018 from over 91% in 2013, and the rate for the highest-earning individuals dropped to 6.7% in 2018 compared with an audit rate of nearly 35% in 2015.
IRS officials have blamed the yearslong drop in audit rates on dwindling agency funding over the past nine years and staff retirements that drain the agency's knowledge base. However, the decline may soon be reversed due to developments that will likely give the IRS more resources than it has had in the past, according to Bryan C. Skarlatos, a partner at Kostelanetz & Fink LLP.
“I'm thinking things are going to start trending up,” he said. “It may take more than a year to get it up, but I think by 2020 you'll see audit rates go up.”
Bryan C. Skarlatos participated in a panel presentation titled “Economic Substance, Judicial Doctrines And Legal Ethics” at PLI's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2019
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, rules of professional responsibility and conduct, including 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.
Chambers USA Recognizes K&F and its Attorneys as Leaders in Tax Controversy and White-Collar Defense
“An Extraordinary Group of Lawyers Who Are Outstanding Individually and Outstanding as a Team”
NEW YORK, NY (April 30, 2019) – Kostelanetz & Fink is pleased to announce that Chambers and Partners has recognized the firm in its 2019 USA Guide. The guide, released April 25, 2019, recognizes K&F and its attorneys in the areas of tax controversy, tax fraud, tax law, and white-collar defense and government investigations. Chambers USA ranks the top lawyers and law firms across all the United States of America through assessment of a firm’s work and opinions from external market sources, with an emphasis on client feedback.
BRYAN C. SKARLATOS QUOTED IN "The $26 Million Question: What Happens if You Don’t File Your Taxes for a Decade?", THE WALL STREET JOURNAL
The IRS can fill out a substitute return for you—and it usually isn’t accurate. And a lot of penalties and interest will accrue.
Even if you don’t go to jail, blowing off the Internal Revenue Service is a really bad idea.
Take Larry Cecil Cabelka of Megargel, Texas. Mr. Cabelka didn’t submit tax returns for 12 years during the 1990s and 2000s, according to a March 26 ruling by a U.S. appeals court. As a result, said the court, he owes the U.S. more than $26 million.
Bryan C. Skarlatos participated in the webinar "Mastering Bitcoin, Blockchain, And Virtual Currency Law" for The Rossdale Group
The huge expansion in Bitcoin & digital currencies in states across the nation and globally has led to a significant need for attorneys proficient in the cutting-edge use of related legal and regulatory issues. The laws vary greatly and have been in flux with the proliferation of Fortune 500 companies, governments, and start-ups seeking to take advantage of this growing use of currency. The faculty for this seminar features several leading authorities on the subject.
Bryan C. Skarlatos participated in the panel titled "Rocks - Partnership Representatives - Hard Places" at the New York State Bar Association Annual Meeting
How can “Partnership Representatives” carry out their responsibilities and wade through the numerous conflicting interests and privacy concerns in light of all the obligations and elections they may have under the new partnership audit rules, the partnership agreement, their own contracts with the partnership, fiduciary obligations, and most importantly, the professional responsibility and ethical rules? Would you want to be a PR?
Megan L. Brackney and Bryan C. Skarlatos quoted in "Partnership Audit Regime Creates Liability Issues for Reps" , Tax Notes
The vast power given to partnership representatives under the centralized audit regime could make them the target of lawsuits, particularly if partners aren’t kept informed about audits.
Limited partners left in the dark could sue representatives under various theories of liability if they’re hit with a surprise tax bill, but succeeding on those claims could be difficult.