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Tag: Megan L. Brackney

OPR’s Star Chamber: Felons And The IRS’s Opaque Sanctions Process

By Megan L. Brackney and Daniel Q. Flesch Tax Notes Federal; Tax Notes State July 2021 Abstract: In this article, Brackney and Flesch examine the lack of transparency in the IRS Office of Professional Responsibility’s sanctions process and explore recently released administrative law judge and Treasury appellate authority decisions relevant

Megan L. Brackney Participates In A Panel Entitled “Tips For Handling Audits Of Pass-Through Entities Under The Centralized Partnership Audit Regime” At The NYU Tax Controversy Forum

On June 24, 2021, Megan L. Brackney participates in a panel entitled "Tips for Handling Audits of Pass-Through Entities Under the Centralized Partnership Audit Regime" at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business. The use of partnerships and

Megan L. Brackney Quoted In Tax Notes Article Entitled “What’s Reasonable for Late-Filed Foreign Information Returns?”

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.

Megan L. Brackney Participates In A Presentation Entitled “Attorney-Client Privilege: The Tax Edition” At New York Law School’s 18th Annual Tax Lawyering Workshop

On April 30, 2021, Megan L. Brackney participates in a presentation entitled "Attorney-Client Privilege: The Tax Edition" at New York Law School’s 18th Annual Tax Lawyering Workshop. New York Law School's Professional Responsibility in Tax Workshop is an annual event put on by the Graduate Tax Program. This year’s theme

The IRS’s Assessment Of Penalties On Substitute Forms 3520-A

By Megan L. Brackney Tax Notes International, Volume 102 Issue 3 Tax Notes Federal, Volume 171 Issue 3 April 19, 2021 In recent months, we have seen several clients being heavily penalized for purportedly late filing Form 3520-A, “Annual Information Return of Foreign Trust With a U.S. Owner,” when they