Protected: White Collar Criminal Investigations Slowing Down? Think Again.
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AMLA 2020: Sweeping New AML Laws Have Broad Impacts on All Financial Crimes
By Don Fort, Christopher M. Ferguson, and Olivia Renensland The White Collar Crime Committee Newsletter, published by the ABA Criminal Justice Section’s White Collar Crime Committee Winter/Spring 2021 On January 1, 2021, following House and Senate overrides of a presidential veto, the National Defense Authorization
PENALTIES—Reconsidering the Reasonable Cause Defense to Late-Filing Penalties and the Impact of the Service’s Clarification of the DIIRSP
By Lawrence Sannicandro Journal of Tax Practice & Procedure Winter 2020 Edition During the 2019 fiscal year, the Internal Revenue Service (“Service” or “IRS”) assessed more than 4.7 million late-filing penalties that cost taxpayers nearly $9.9 billion. These late-filing penalties account for an incredible 24%
The New Age of International Criminal Tax Enforcement
By Caroline D. Ciraolo and Jon D. (Don) Fort Journal of Tax Practice & Procedure Winter 2020 Edition The current global economic landscape presents challenges for tax authorities around the world—reduced tax revenue, limited resources for compliance and enforcement, and increased risk of noncompliance. In the
When Client Relationships Don’t End Amicably
By Dan Davidson The CPA Journal December 2020/January 2021 Edition It is never pleasant when a client relationship ends on less than amicable terms. This is especially true when the relationship’s demise leads to litigation. A contract dispute that was recently litigated in bankruptcy court [In
Tax Treatment of Liquidations of Partnership Interests
By Eric Smith The CPA Journal December 2020/January 2021 Edition The liquidation of a partner’s entire partnership interest can take various forms, including payment made by the partnership to the retiring partner in complete redemption of the partner’s interest or a sale of such interest to
Mitigating IRS Cryptocurrency Enforcement Risk in 2021
The high-stakes game of chicken regarding the IRS's enforcement of tax violations involving cryptocurrency holders is poised to move to the next level in 2021, K&F Director of Investigations Don Fort and Partner Lawrence Sannicandro explain in a recent Law360 article. After several years of
The Impact of the IRS’s Clarification of the DIIRSP
Recent clarifications to the Delinquent International Information Return Submission Procedures (“DIIRSP”) remind taxpayers and their advisors of the need to understand the standards, case law, and administrative guidance that apply to requests to have late-filing penalties abated on the ground of reasonable cause. In June
More Bankruptcies, More Opportunities and Challenges for CPAs
By: Sidney Kess, Alan Gassman, and Aaron Slavutin The CPA Journal October/November 2020 From name-brand corporations like JCPenney and Neiman Marcus to small and mid-sized companies, businesses of all sizes are responding to pandemic-related lockdowns by seeking refuge in bankruptcy. Legal services provider Epiq has reported
Beyond Tax: Contested Election, Trade War, and the Post-COVID World
By: Sidney Kess and Thomas K. Lauletta Estate Planning Review—THE JOURNAL VOLUME 46 | ISSUE 10 | OCTOBER 22, 2020 Many experts are focusing primarily on the tax issues that are likely to arise as a result of the election, such as changes in the wealth