U.S. taxpayers and residents are required under the Internal Revenue Code and the Bank Secrecy Act to report their relationship to foreign accounts and assets on an annual basis. The IRS and the Department of Justice have significantly increased enforcement of these reporting requirements through criminal prosecutions and the imposition of crushing civil penalties that can come when taxpayers are not compliant. This panel explored the current state of IRS and DOJ civil and criminal enforcement with respect to taxpayers who have not complied with FBAR (Report of Foreign Bank and Financial Accounts) and FATCA (Foreign Account Tax Compliance Act) reporting requirements. The panel also covered pathways to compliance for the non-compliant taxpayer, including the IRS’s Voluntary Disclosure Practice.

New rules from the First Step Act and sentencing guidelines amendments could be on display when judges start deciding on punishment for participants in the recent massive college bribery scheme.

The sentencing hearings will begin in June for those facing charges, including tax and fraud charges, in the “Operation Varsity Blues” college admissions scandal, with the hearings for the parents who have pleaded guilty to start in the fall.

Ever since CI started talking about its new data analytics strategy, the division has been fielding privacy and disclosure concerns.

Asked if the IRS has the right to apply its new sophisticated data analytics tools to a taxpayer’s data, Michael Sardar of Kostelanetz & Fink LLP said that the standard search and seizure analyses involve situations in which the government needs to spend a large amount of resources — for example, with visual surveillance or telephone wiretapping. “There’s a parallel in terms of how much effort the government has to put in versus what they are going to get out of it, and that’s how you determine
what is reasonable,” he said.

A panel of experts updated attendees on the latest priorities and trends in IRS criminal Enforcement, including cyber-crimes, crypto-currency, marijuana, payroll tax crimes, money laundering and good-old-fashioned income tax evasion.

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Moderator: Lisa E. Perkins, Green & Sklarz LLC, West Hartford, CT

Panelists:

• Kristina O’Connell, Special-Agent In-Charge, IRS Criminal Investigation, Boston Field Office
• Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ
• Michael Sardar, Esq., Kostelanetz & Fink, LLP, Washington, DC

Important developments in Offshore Compliance and Enforcement.

Brought to you by the American Academy of Matrimonial Lawyers (AAML) and Business Valuation Resources (BVR), the National Divorce Conference brought together the leading matrimonial attorneys and financial experts for the only event of its kind. 

2019 promises to be a key year for the tax bar. With landmark administrative guidance in the wake of tax reform, practitioners will be contending with fast-paced developments that will have immediate and immense effects. 

This session covered issues that arise for the tax-preparer when working with clients who don’t have adequate records. Topics covered in this webinar included schedule C pitfalls, the Earned Income Tax Credit (EITC), use of reconstructions and estimates, the Cohan rule, and the AICPA Statement on Standards with respect to the use of estimates. 

Important Developments (Civil) – Sara G. Neill and Michelle F. Schwerin, Capes Sokol Goodman Sarachan PC, St. Louis, MO; Important Developments (Criminal) – Evan J. Davis, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; International Tax Enforcement – Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC and Joseph M. Erwin, Dallas, TX; IRS Investigations and Practices – Michael A. Villa Jr., Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX and Eric L. Green, Green & Sklarz LLC, New Haven, CT.

NEW YORK (Jan. 9, 2018) -- Kostelanetz & Fink is pleased to announce that Michael Sardar has been named a partner in the firm.  Mr. Sardar joined Kostelanetz & Fink’s New York office in 2009.   Mr. Sardar handles a wide variety of tax controversy and white collar criminal defense matters.  He represents clients before the Internal Revenue Service, state tax authorities, the Department of Justice, and local prosecutors.