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.
Michael Sardar presented "Working with Schedule C Taxpayers Without Complete Records: Reconstruction, Estimates, and Best Practices" at the Sid Kess's "Dealing with the IRS" seminar at Baruch College on Dec. 4.
Michael Sardar presented "Working with Schedule C Taxpayers Without Complete Records: Reconstruction, Estimates, and Best Practices" at the Sid Kess's "Dealing with the IRS" seminar at Baruch College on Dec. 4.
In the event of a loss of client records or due to poor record keeping, a paid preparer may need to help his client reconstruct the records and/or make estimates. This session covered tips and ideas on how to handle such issues from tax-return preparation through audit and will include a review of the Schedule C Form, common Schedule C pitfalls, and the best practices for how the tax return preparer and client can utilize estimates and reconstructions in these situations. The session also addressed the Cohan rule and the AICPA Statement on Standards with respect to the use of estimates.
Michael Sardar moderated the panel "Ethical Obligations To Report Misconduct by Other Practitioners and Taxpayers" at the 2019 New England IRS Representation Conference in Uncasville, CT
Tax practitioners should be mindful of their ethical obligation to report tax-related misconduct under the internal revenue laws, the Model Rules of Professional Conduct, and Circular 230. This group of experienced panelists examined when, whether, and how to complain about professional misconduct by private practice and government attorneys or the Court. The panelists also discussed when, whether, and how to report tax-related misconduct by unscrupulous tax professionals.
Michael Sardar Participated on the Panel Entitled "Reports of Subcommittees on Important Developments: Offshore Compliance and Enforcement," at the ABA Tax Section 2019 Fall Meeting on October 5, 2019
Michael Sardar participated in a discussion of offshore compliance and enforcement, as part of a larger panel on subcommittee reports on important developments.
Offshore Compliance and Enforcement Panelists: Arielle Borsos, Caplin & Drysdale, Chtd, Washington, DC, Victor Jaramillo, Caplin & Drysdale, Chtd, Washington, DC, Michael Sardar, Kostelanetz & Fink LLP, New York, New York.
Kostelanetz & Fink Attorneys Recognized By New York Metro Area Super Lawyers
NEW YORK CITY, NY (September 12, 2019) – Kostelanetz & Fink is pleased to announce that nine attorneys at the firm, including seven partners, have been selected for inclusion in the 2019 New York Metro “Super Lawyers” list, recognizing the firm’s experience and skill in the areas of Tax, Criminal Defense: White Collar, and Business Litigation.
Michael Sardar presented the CPE/CLE course "Working with Schedule C Taxpayers Without Complete Records: Reconstruction, Estimates, and Best Practices" at The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference
In the event of a loss of client records or due to poor record keeping, a paid preparer may need to help his client reconstruct the records and/or make estimates. This session covered tips and ideas on how to handle such issues from tax-return preparation through audit and will include a review of the Schedule C Form, common Schedule C pitfalls, and the best practices for how the tax return preparer and client can utilize estimates and reconstructions in these situations. The session also addressed the Cohan rule and the AICPA Statement on Standards with respect to the use of estimates.
Michael Sardar and Caroline Ciraolo participated in a panel titled "IRS Voluntary Disclosures: Past, Present, And Future" at The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference
The IRS has offered noncompliant taxpayers a path to come into compliance for decades. First, under the Internal Revenue Manual voluntary disclosure practice, and then under the historic Offshore Voluntary Disclosure Programs. In November 2018, the IRS announced new provisions that will apply to all future domestic and offshore voluntary disclosures. Since then, practitioners have been debating the new voluntary disclosure practice and its impact on clients, and taxpayers are wondering if this is the best approach to resolve outstanding issues. The panelists outlined the new framework and engaged in a spirited discussion regarding various open issues and best practices.
Michael Sardar moderated a panel titled "Areas of Controversy Under the TCJA" at the NYU SCPS 11th Annual Tax Controversy Forum
The TCJA made sweeping changes to the Internal Revenue Code, and while Treasury and the IRS have done a Herculean job of providing guidance, many of the changes are complex and there is scant legislative history to reveal what Congress intended. Certain provisions of the TCJA will be caught in a cross-current of complexity and ambiguity that may lead some taxpayers to take aggressive reporting positions. This panel identified some of those provisions and the areas in which controversies are likely to ensue.
