Publications Archives - Page 5 of 26

The First-Time Abatement Policy—Harsh Realities And Strategic Considerations

By Garrett L. Brodeur ABA Tax Times May 2022 Issue First-Time Abatement The IRS implemented a first-time abatement (FTA) policy in 2001 to provide relief from penalties in a single year for failure to file, failure to pay, or failure to deposit under certain circumstances.

The Trust Fund Recovery Penalty: Who Is Responsible To Pay?

By Juliet L. Fink Practical Tax Strategies June 2022 Edition If an employer willfully fails to withhold or remit payroll taxes, the IRS can impose a Trust Fund Recovery Penalty (“TFRP”) against every individual who is determined to be a “responsible person” of the employer. The

Tax Controversies: Audits, Investigation, Trials (41st edition)

By: Robert S. Fink LexisNexis 41st Ed. 2022 The 41st edition of “Tax Controversies: Audits, Investigations, Trials” has been published and is available on Lexis-Nexis. Authored by Kostelanetz & Fink co-founder Robert S. Fink and the attorneys of Kostelanetz & Fink, Tax Controversies is the recognized guide

Op-Ed: City Comptroller Should Use All Tools In His Arsenal To Help Human-Services Sector

By Claude M. Millman and Mariana Gusdorf Crain's New York Business May 17, 2022 Mayor Eric Adams and city Comptroller Brad Lander have endorsed five recommendations to improve New York’s system for processing contracts and payments to human-services contractors, a sector that employs more than

The IRS’ Authority To Seize Assets In Foreign Jurisdictions To Satisfy FBAR Penalties

By Megan L. Brackney and Luke H. Ryan The Journal of Tax Practice & Procedure Spring 2022 Abstract: In this article, Brackney and Ryan discuss the Internal Revenue Service’s (IRS’) ability to seize offshore assets to collect delinquent Report of Foreign Bank and Financial Accounts

Recent Developments In FBAR Jurisprudence

By Usman Mohammad and Michael Gelb The CPA Journal, Tax Practice & Procedure Column December 2021 Issue Failing to report foreign bank accounts on a Report of Foreign Bank and Financial Accounts (FBAR) form can carry severe financial consequences. The civil penalty for non-willful violations

The IRS’s Big Plans For Big Data

By Christopher M. Ferguson CPA Journal August/September 2021 Faced with shrinking budgets and resources, for more than a decade the IRS has been forced to do more with less. It has responded by turning to big data analytics. In recent years, the IRS has amassed

John Doe Summonses, Cryptocurrency, and the Taxpayer First Act

By Megan L. Brackney and Jas Singh Tax Notes State October 2021 Abstract: In this article, Brackney and Singh explore the effect of the Taxpayer First Act’s procedural requirement that John Doe summonses be “narrowly tailored to information that pertains to the failure (or potential

Calling For Backup: When Do You (Or Your Clients) Need To Bring In Counsel?

By Caroline D. Ciraolo EA Journal September/October 2021, Vol.39 No.5 Tax controversy practitioners include various professionals with diverse experience and expertise. From tax return preparers to certified public accountants (CPAs) and enrolled agents (EAs) to tax attorneys, a client has many options in seeking advice

Increasing Diversity In Tax Law

By Destiny Reese The Federal Lawyer September/October 2021 Unfortunately, few undergraduate and law school students aspire to become tax attorneys. This is primarily because tax law is often mistaken to be solely concerned with preparing tax returns for wealthy people or working for the Internal