By Bryan C. Skarlatos and Caroline Rule Journal of the American Academy of Matrimonial Lawyers Volume 33 Issue 2 (2021) When it comes to unreported foreign bank accounts, there is good news and bad news. The good news is that a previously unreported foreign bank account can dramatically increase the
The Ninth Circuit Court of Appeals recently ruled in favor of a taxpayer subject to a non-willful civil penalty for failure to timely file an accurate Foreign Bank Account Report (FBAR), agreeing with a position advanced in a friend of the court brief written by Kostelanetz & Fink partners Caroline
On December 11, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Notice 2020-1 (the Notice) which extends until April 15, 2022 the deadline to file Reports of Foreign Bank and Financial Accounts (FBARs) (FinCEN Form 114) for certain officers, employees, or agents of a U.S. entity who have signature or
By: Caroline Rule Journal of Tax Practice & Procedure Fall 2020 Edition This article will discuss cases after June 2019 that have followed, rejected, or partially relied on the precedents of Williams and McBride, which cases include language to the effect that, if a taxpayer signs a Form 1040 income tax
NEW YORK CITY, NY (September 29, 2020) – Kostelanetz & Fink is pleased to announce that 10 attorneys at the firm have been selected for inclusion in the 2020 New York Metro Super Lawyers list, recognizing the firm’s experience and skill in the areas of Tax, Criminal Defense: White Collar,
By: Caroline Rule Journal of Tax Practice & Procedure Summer 2020 Edition Recent litigation has focused on the government’s new position that the $10,000 non-willful civil FBAR penalty applies per account listed on an non-willfully untimely-filed annual FBAR—a Report of Foreign Bank or Financial Accounts that must be filed by a U.S. person “who
Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2), has been selected for inclusion
Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2), has been selected for inclusion
By Caroline Rule and Bob Fink Law 360 Twenty years ago, we put forward what was then a novel concept — that the IRS and the U.S. Department of Justice were misusing the tax code to make their jobs easier. Our topic was the misuse of a statute that, we contended, was reserved for prosecuting the deliberate
