Megan Brackney presented a webinar entitled "IRS Summons and Other Methods of Obtaining Taxpayer Information, Enforcement, and Defenses" for Celesq Attorneys Ed Center, on May 21, 2020
The IRS has several methods for obtaining information about taxpayers. This program discussed the IRS’s methods of obtaining information, focusing primarily on the IRS’s summons authority, including the scope of that authority, taxpayer’s rights and privileges, summons enforcement litigation, and the attorney’s ethical obligations when responding to IRS requests for information under Circular 230.
Megan Brackney presented a webinar entitled "Form 8300 Reporting Requirements and Penalties" for the CPA Academy, on May 13, 2020
This program discussed the requirements to file Forms 8300 to report cash transactions in a trade or business of over $10,000 and to furnish annual statements to customers. Ms. Brackney outlined the basics of Form 8300 compliance, and then went into further discussion about the potential penalties, defenses to penalties, and the methods of challenging Form 8300 penalties.
Megan Brackney presented a webinar entitled "The New IRS Fraud Enforcement Office: Enforcement & Consequences of Tax Fraud," for the CPA Academy, on April 7, 2020
Now is a good time to enhance your understanding of tax fraud and the IRS’s antifraud enforcement tools The IRS has created a new Fraud Enforcement Office to develop increased enforcement, both with criminal referrals from the field and additional civil fraud penalties. This webinar discussed the indicia of fraud, how the IRS identifies and proves fraud, and the civil and criminal consequences of tax fraud, and the relevant procedures.
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.”
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.”
Drawing on their deep experience representing clients facing some of the most challenging and complex tax controversy matters, Kostelanetz & Fink partners Bryan Skarlatos and Megan Brackney have for years been bringing their expertise into the classroom as adjunct professors at New York University School of Law.
Megan L. Brackney presented the webinar, “IRS Summons: Use, Scope, and Enforcement in 2020” for CPA Academy on February 20, 2020
The IRS has various methods of obtaining information from and about taxpayers. In this program, attorney Megan L. Brackney will discuss the IRS’s use of summonses to obtain information from taxpayers and third parties, the scope of the IRS’s authority, and summons enforcement. The discussion will include the IRS’s use of John Doe Summonses and Formal Document Requests. We will also discuss taxpayer rights and defenses, including the assertion of privileges, such as attorney-client, work product, federally-authorized tax practitioner, and Fifth Amendment privileges.
Megan Brackney presented a CLE program entitled “Walking Through the Various States of the Partnership Audit Rule Process" on December 4, 2019
Megan Brackney presented at the American Law Institute course entitled “Representing Partnerships in Tax Audits, Controversies, and Litigation with the IRS,” on December 4, 2019.
The new partnership audit rules represent the most substantial change to audits in almost four decades. For partnerships, including LLCs taxed as partnerships, the opening of audits at this time and into the future will be governed by the new regime. In application, the new audit rules can significantly change audits and litigations, including who is responsible for tax payments and how deficiencies are attributed to partnerships, equating to a monumental tax procedure paradigm shift. Many practitioners possess a general understanding of these changes, but few possess an in-depth understanding of the impact these new rules will have. This program got down to the brass tacks of what the new audit rules look like in action - at formation, during the audit process, and on appeal, so that you can make more out of your pre-game planning!