Megan Brackney presented at the American Law Institute course entitled “Representing Partnerships in Tax Audits, Controversies, and Litigation with the IRS,” on December 4, 2019. The new partnership audit rules represent the most substantial change to audits in almost four decades. For partnerships, including LLCs taxed as partnerships, the opening
Information is power and, in civil audits and criminal investigations, the government seeks to identify and obtain as much information as possible. To the extent such information falls within a recognized legal privilege, it is up to counsel for the taxpayer or target to timely and properly assert the applicable
Now is a good time to enhance your understanding of tax fraud and the IRS’s antifraud enforcement tools The IRS has created a new Fraud Enforcement Office to develop increased enforcement, both with criminal referrals from the field and additional civil fraud penalties. This webinar discusses the indicia of fraud,
This program discusses the requirements to file Forms 8300 to report cash transactions in a trade or business of over $10,000 and to furnish annual statements to customers. Ms. Brackney outlines the basics of Form 8300 compliance, and then goes into further discussion about the potential penalties, defenses to penalties,
The IRS has several methods for obtaining information about taxpayers. This program discussed the IRS’s methods of obtaining information, focusing primarily on the IRS’s summons authority, including the scope of that authority, taxpayer’s rights and privileges, summons enforcement litigation, and the attorney’s ethical obligations when responding to IRS requests for
On October 1, 2020, Megan L. Brackney participates in a panel entitled “Who is a Return Preparer Under 6694?” at the ABA’s 2020 Fall Tax Meeting, as part of its programming on Standards of Tax Practice. Who is a Return Preparer Under 6694? This once sleepy backwater of the Code
On October 8, 2020, Megan L. Brackney discusses the requirements for filing Forms 8300 and sending payee statements, the penalties for non-compliance, and defenses to penalties. Course objectives included: identifying transactions that must be reported on Form 8300; reviewing Form 8300 preparation; identifying the penalties or failure to file Form
On April 28, 2022, Megan L. Brackney participates in a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” for “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2022 Chicago” hosted by the Practising Law Institute
Megan L. Brackney was quoted in a recent Tax Notes article entitled “A Look Ahead: Mo’ BBA Audits, Mo’ Problems,” published on December 30, 2021. Brackney analyzes potential issues with the implementation of Bipartisan Budget Act “BBA” procedures to IRS partnership audits. The article notes: According to Megan L. Brackney
On January 13, 2022, Megan L. Brackney teaches a course entitled “Ethical Issues in Practice Before the IRS” for CPA Academy. Course Description: This session covers the provisions of Circular 230 and the AICPA Statements on Standards for Tax Services that apply when interacting with the IRS during audits, appeals,
