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.
In a recent New York Times article entitled “An Accidental Disclosure Exposes a $1 Billion Tax Fight With Bristol Myers,” Bryan C. Skarlatos weighed in on the potential outcome of a tax controversy between the Internal Revenue Service and Bristol Myers Squibb, an American drugmaker. The dispute with the IRS
By Dan Davidson and Destiny Reese PLI Chronicle March 2021 Issue Over 70% of federal tax filings in 2019—including almost 90% of individual income tax returns—were filed electronically. Yet, as tax practitioners know, many federal tax forms continue to require “wet” signatures. Even before the COVID-19 pandemic, there were calls for
The Ninth Circuit Court of Appeals recently ruled in favor of a taxpayer subject to a non-willful civil penalty for failure to timely file an accurate Foreign Bank Account Report (FBAR), agreeing with a position advanced in a friend of the court brief written by Kostelanetz & Fink partners Caroline
By Christopher M. Ferguson and Hannah Ambinder On March 3, 2021, the Financial Action Task Force (FATF) and Egmont Group of Financial Intelligence Units (Egmont Group) released Trade-Based Money Laundering: Risk Indicators, a publication outlining anti-money laundering risk factors. The FATF Report’s purpose is to improve the identification of suspicious
This spring, Caroline Ciraolo and Robert Russell will again bring their decades of experience in federal tax enforcement and tax controversy matters to Georgetown University Law Center and Graduate Tax Program in a class entitled, “International Tax Controversy.” Professors Ciraolo and Russell concentrate the course on real world civil and
Caroline D. Ciraolo and Paul Butler were quoted in a recent Law360 article entitled “Pa. Judge’s Ruling in FBAR Case Could Add to Gov’t Arsenal,” published on January 25, 2021. Ciraolo and Butler discuss the implications of a recent court ruling on the imposition of willful FBAR penalties. The article
On December 11, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Notice 2020-1 (the Notice) which extends until April 15, 2022 the deadline to file Reports of Foreign Bank and Financial Accounts (FBARs) (FinCEN Form 114) for certain officers, employees, or agents of a U.S. entity who have signature or
