The Bipartisan Budget Act of 2015, which President Obama signed into lawonNovember, 2015, repealed the complex and much-criticized TEFRA partnership entity-level audit rules, including the electing large partnership rules. On December 18, 2015, Congress passed, and President Obama signed into law, the Protecting Americans From Tax Hikes (PATH) Act of 2015. This act sets forth certain corrections to the new audit rules.
In this course, Jerald David August and Megan L. Brackney will review the updates to the TEFRA Partnership Audit Rules Repeal.
The 2016 Private Wealth and Taxation Institute was an exceptional program this year. It was highly informative for private clients and their advisors. The speakers will included Paul Lee, from Northern Trust, Gideon Rothschild, Sandy Schlesinger, Professor Jerome Hesch, Dick Nenno and Sharon Klein from Wilmington Trust, Bryan C. Skarlatos and Megan L. Brackney from Kostelanetz & Fink, LLP, and Jeffrey Goldenberg from Goldman Sachs to name a few. In addition, there was also be a strong representation from the public sector including the Taxpayer Advocates for the Federal, State, and NYC governments, a Tax Court Judge, and the Suffolk County Surrogate Court Judge. Of course, there was plenty of local talent that presented, including several attorneys from The Private Wealth & Taxation Group of Meltzer Lippe and presenters from other Long Island Law Firms and Accounting Firms.
Years ago, women tax lawyers were a rare sighting at the Tax Section meetings. Looking around we know that the demographics have changed dramatically. Where are women tax lawyers in government, private practice, teaching and the judiciary and how have they impacted the ever-changing tax laws. Panelists reflected upon what inspired them to become tax lawyers, what have been the rewards and what have been the challenges.
Time Will Not make This Problem Disappear: The Open-Ended Statute of Limitations for Taxpayers with Delinquent Foreign Information Returns
By Megan L Brackney
ABA Tax Times - Vol. 35 No. 2
February 2016 Edition
Although section 6501(c)(8) has been in the Code for several years, many tax practitioners remain unaware of this exception to the general three-year statute of limitations for assessment of tax for delinquent foreign information returns. This exception can significantly influence a taxpayer’s decision as to whether, and how, to correct past non-compliance. This article first discusses the exception, and then describes the alternative methods for late filing of foreign information returns.
Megan L. Brackney Presented, "To File or Not to File – That is the Question” at American Bar Association, Section of Taxation, 2016 Midyear Meeting
Los Angeles, CA welcomed the ABA Section of Taxation to the 2016 Midyear Meeting on January 28-30, 2016.
Attendees were able to explore a full range of current tax issues in over 35 areas of tax law with Committee and Subcommittee programming on Friday and Saturday. Featured as a speaker was Megan L. Brackney, of Kostelantez & Fink LLP, presenting "To File or Not to File - That is the Question".
November 05, 2015
Tax law is complicated and the answers are not always clear. When a client wants you to take a position on a tax return, such as reporting income as capital gain, or taking a deduction, how sure do you have to be that your position is correct? If the IRS audits the position, when can the client be subject to penalties? When can you, the preparer, be subject to penalties? When you are collecting information from your client, can you just accept what your client tells you, or do you have to audit the client’s representations? What are your ethical responsibilities under the Statements of Standards for Tax Services when confronted with unclear positions? This program will address these and other questions to help you provide your clients with the best advice possible while avoiding penalties and complying with your ethical obligations.
On October 20, 2015, Megan L Brackney presented "Fixing Common Tax Problems" at the 2015 Zicklin Tax Seminar 2. Through the Zicklin Tax Series, Baruch provides alumni and other members of the tax community with an opportunity to earn up to 24 hours of CPE in taxation over the course of three seminars.
Megan L. Brackney presented an ethics-based course, "Fixing Common Tax Problems", on October 8, 2015, for the first day of the two-day ALI event, Handling a Tax Controversy 2015: Current Trends in Civil Tax Controversies and Litigation.
The trusted tool for tax practitioners, Handling a Tax Controversy 2015 provides insights and practical strategies on all aspects of handling federal tax controversies. The outstanding faculty - including U.S. Tax Court judges, current and former senior government officials, and top U.S. and foreign tax controversy practitioners - explores the following topics and more:
- Current issues at IRS examinations and appeals
- Future of international information sharing
- Handling FOIA requests and litigation
- Current issues in TEFRA partnership exams
- Courtroom technology strategies and expert witness tactics
- Litigating FBAR and tax fraud cases in U.S. District Court
On Tuesday July 14, 2015, American Law Institute presents the audio webcast, FATCA for Estate Planners: A Practical Approach. Jerry August of Kostelanetz & Fink, LLP will facilitate the audio webcast as the Planning Chair and Megan L. Brackney will participate as a Faculty role for the conversation.
Megan L. Brackney presents a webinar on June 25,2015 for AFDA White Collar Roundtable, "White Collar Roundtable".