Garrett L. Brodeur Archives

New Crypto Tax Question Foreshadows IRS Enforcement Priorities

By Garrett L. Brodeur Tax Notes Federal September 5, 2022 Abstract: In this article, Brodeur argues that recent changes to the Form 1040 cryptocurrency question highlight an area in which the IRS sees significant enforcement potential and foreshadow a continued shift in the agency’s priorities. In late July, the IRS

Old Dog, New Tricks? The New York FCA and Crypto-Tax Compliance

By Garrett L. Brodeur and David Taylor Tax Notes State July 25, 2022 Abstract: In this article, Brodeur and Taylor examine the New York Attorney General’s intention to use the state’s False Claims Act to ensure cryptocurrency tax compliance, which they argue raises important tax policy concerns and should serve

U.S. Supreme Court Agrees to Review Major FBAR Penalties Case

On June 21, 2022, the U.S. Supreme Court agreed to hear a major case regarding IRS penalties relating to Reports of Foreign Bank and Financial Accounts (FBARs). Kostelanetz & Fink represents the American College of Tax Counsel (the “College”), which filed an amicus brief in Alexandru Bittner v. United States

‘Flat Sum’ Settlements: An ‘End Run’ Around New York’s Reporting Requirements?

By Garrett L. Brodeur The CPA Journal, Tax Practice & Procedure Column March/April 2022 Issue In computing a state resident’s adjusted gross income for personal income tax purposes, New York, like many states, starts with the individual’s federal adjusted gross income and makes certain additions or subtractions to arrive at

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 data suggest that the

K&F Files Amicus Brief Asking SCOTUS To Review Key FBAR Penalties Case

Kostelanetz & Fink served as counsel of record on behalf of the American College of Tax Counsel, which filed an amicus brief in the case of Alexandru Bittner v. United States on April 1, 2022. The College’s brief argued in support of the petition for a writ of certiorari seeking

Tag: Garrett L. Brodeur

New Crypto Tax Question Foreshadows IRS Enforcement Priorities

Old Dog, New Tricks? The New York FCA and Crypto-Tax Compliance

U.S. Supreme Court Agrees to Review Major FBAR Penalties Case

‘Flat Sum’ Settlements: An ‘End Run’ Around New York’s Reporting Requirements?

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

K&F Files Amicus Brief Asking SCOTUS To Review Key FBAR Penalties Case

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