Bryan C. Skarlatos, partner at Kostelanetz LLP, was quoted in an article published in Tax Notes on August 23rd, 2023 titled “The FATCA Haystack Remains Just That.” The article discusses unknowns regarding data collected by the Internal Revenue Service through the Foreign Account Tax Compliance Act. Though the IRS strategic
Caroline D. Ciraolo was quoted in a Tax Notes article titled “IRS Penalty Practice May Be Due for Reset,” published on August 16, 2023. The article addresses the current state of penalty administration and notes Caroline Ciraolo’s concerns regarding the Internal Revenue Service’s current approach to the consideration and assessment
On Tuesday, September 5th, 2023, Caroline D. Ciraolo presents a keynote address titled “The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement” at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge. Date: 8:00am BST (U.K. Time) on Tuesday September 5th, 2023. A full
On August 15th, 2023, Caroline Ciraolo participates in a webinar panel titled “IRS Penalty Policy and Practice” as part of a webinar series titled “Transforming Tax Administration” presented by Center for Taxpayer Rights. Description: Center for Taxpayer Rights presents a series of webinars from March 23, 2023 through August 31,
On August 22, 2023, Heather Fincher participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford. CPE Credit is offered for this event. Description: This course provides tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact
The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60 participants engaging in a ”[h]igh-dollar
In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et al. v. United States, Case
As reported in our last news alert, the IRS is moving aggressively to investigate Malta Pension Plans. This is after naming Malta Pension Plans to the IRS’s Dirty Dozen (its annual list of abusive transactions), issuing a Competent Authority Arrangement walking back the tax benefits otherwise allowed under the U.S.-Malta
