Kostelanetz & Fink has filed an amicus brief on behalf of the American College of Tax Counsel (“ACTC”) in the U.S. Supreme Court case of Alexandru Bittner v. United States (No. 21-1195). The brief asks the Supreme Court to reverse a decision by the Fifth Circuit Court of Appeals that
On August 16, 2022, the Department of Justice published a press release announcing that a federal court in the Central District of California has authorized the IRS to serve a John Doe summons on the cryptocurrency prime dealer SFOX. That summons directs SFOX to identify and produce records relating to
As we previously reported, the IRS recently updated Form 14457 (Voluntary Disclosure Practice Preclearance Request and Application) to include a section requiring disclosure of virtual currency. Virtual currency is a digital representation of value stored in electronic form and usable as a medium for exchange. Virtual currency can sometimes operate
By Juliet L. Fink On February 15, 2022, the IRS announced updates and additions, both technical and substantive, to the Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, and its instructions. The updates reflect input from practitioners and taxpayers and take into account trends in the type of financial
Don Fort was quoted in a recent Politico article entitled “What’s the IRS have to do with Russia and Ukraine?” published on February 28, 2022. The article notes: Experts say that the agency would be in a good position to track Russian assets, including those of President Vladimir Putin and
Don Fort was quoted in a recent Tax Notes article entitled “IRS Updates Voluntary Disclosure Form With Electronic Bent,” published on February 16, 2022. The article notes: Don Fort of Kostelanetz & Fink LLP told Tax Notes the decision to allow electronic signatures and electronic fax submissions will always receive a
Megan L. Brackney was quoted in a recent Forbes article entitled “Cryptocurrency Front And Center In Revised IRS Voluntary Disclosure Practice,” published on February 15, 2022. Brackney analyzes the implications of the recent updates to the IRS’s Voluntary Disclosure Practice Preclearance Request and Application on both tax practitioners and taxpayers.
On January 13, 2022, Him Das, Acting Director of the Financial Crimes Enforcement Network (FinCEN), addressed the annual Financial Crimes Enforcement Conference hosted by the American Bankers Association and American Bar Association to discuss FinCEN’s changing approach to anti-money laundering and counter-terrorist financing (AML/CFT). FinCEN is a bureau of the