Caroline D. Ciraolo was quoted in a recent Tax Notes article entitled “Maryland Tax Court Won’t Issue Opinion on Foreign Earned Income Matter,” published on October 22, 2021. The article addresses the refusal of the Maryland Tax Court to issue a decision on the merits regarding Maryland taxpayers’ right to
Robert M. Russell was quoted in a recent Tax Notes article entitled “International Tax Draft Offers New Details, but Major Gaps Remain” published on August 26, 2021. Russell comments on the latest draft international tax proposal from Senate Finance Committee Democrats, released on August 25, 2021. The article notes: Robert
Caroline D. Ciraolo was quoted in a recent Tax Notes article entitled “Panamanian Summons Seen as Better Path to Law Firm Client Info,” published on August 11, 2021. The article addresses the John Doe summons authorized on July 15, 2021 to obtain information from third parties – shipping services and
Robert M. Russell, a member of the The American Institute of Certified Public Accountants, was appointed as Chair of the International Technical Resource Panel (TRP) for the 2021-2022 committee year. The International TRP acts as the primary representative for the AICPA before Congress, Treasury, and the IRS on legislative and
Megan L. Brackney was quoted in a recent Tax Notes article entitled “What’s Reasonable for Late-Filed Foreign Information Returns?,” published on June 7, 2021. Brackney discusses the IRS’ practice of automatically assessing penalties on taxpayers who file late international information returns. The article notes: “It’s incredibly frustrating,” said Megan L.
Caroline D. Ciraolo was quoted in a recent Law360 article entitled “DOJ Official Sees Potential Uptick In Asset Repatriation Efforts,” published on May 12, 2021. Ciraolo continues a discussion that took place during the “Collection Abroad, Including Collection of Title 26 and Title 31 International Information Return Penalties” panel at
Robert M. Russell was quoted in a recent Tax Notes article entitled “Senate International Plan Not Without Taxpayer ‘Silver Linings,’” published on April 15, 2021. Russell comments on various proposals within the Senate Democrats’ international tax framework, released on April 5, 2021. The article notes: “In those cases where BEAT’s
The Joint Chiefs of Global Tax Enforcement (J5)— tax authorities of Australia, Canada, Holland, the UK, and the US—recently convened investigators, cryptocurrency experts, and data scientists in a virtual event, “The Challenge,” where the J5 honed in on developing leads and jumpstarting investigations into criminals’ use of the FINtech industry.