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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

Indigent Access To Justice Debated In Luxury Condo Appeal

By Claude M. Millman, with Russell A.S. Wirth New York Law Journal October 1, 2020 The New York State Court of Appeals is poised to hear oral argument in a case about the financing of a luxury, residential tower on Sutton Place in Manhattan—but some not-for-profits are