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Tag: International Tax Controversies

AMLA 2020: Sweeping New AML Laws Have Broad Impacts on All Financial Crimes

By Don Fort, Christopher M. Ferguson, and Olivia Renensland The White Collar Crime Committee Newsletter, published by the ABA Criminal Justice Section’s White Collar Crime Committee Winter/Spring 2021 On January 1, 2021, following House and Senate overrides of a presidential veto, the National Defense Authorization Act (“NDAA”) for Fiscal Year

The New Age of International Criminal Tax Enforcement

By Caroline D. Ciraolo and Jon D. (Don) Fort Journal of Tax Practice & Procedure Winter 2020 Edition The current global economic landscape presents challenges for tax authorities around the world—reduced tax revenue, limited resources for compliance and enforcement, and increased risk of noncompliance. In the face of such challenges, governments

The Impact of the IRS’s Clarification of the DIIRSP

Recent clarifications to the Delinquent International Information Return Submission Procedures (“DIIRSP”) remind taxpayers and their advisors of the need to understand the standards, case law, and administrative guidance that apply to requests to have late-filing penalties abated on the ground of reasonable cause. In June 2014, the Internal Revenue Service’s

Two Georgetown Law School Students Complete Their K&F Externships

This Fall, K&F hosted two students completing Georgetown Law School’s LLM program in tax law.  Sarah McIntosh and Sadi Moradi joined us as externs while they studied post-graduate level tax law at Georgetown.  Ms. McIntosh expects to earn her LLM this Spring and has previously interned at the Office of