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
Robert M. Russell was quoted in a recent Law360 article entitled “Speed of TCJA Passage May Handicap Treasury in Disputes,” published on March 31, 2021. Russell observes that the swift passage of the TCJA has led to a host of regulatory disputes with the Treasury and Internal Revenue Service which
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
Robert M. Russell was quoted in a recent Tax Notes article entitled “LB&I Campaigns Aim to Advise Taxpayers, Not Increase Audits,” published on January 29, 2021. Russell observes that some LB&I compliance campaign treatment streams have raised questions from taxpayers. The article notes: Robert Russell of Kostelanetz & Fink LLP
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
Robert M. Russell was quoted in a Tax Notes article entitled “Transition Tax Campaign’s Focus on E&P Concerns Practitioners,” published on December 3, 2020. Russell observes that return preparers were concerned about the starting point of determining E&P, given that taxpayers may not possess the best records for past years.
On December 2, 2020, Robert M. Russell participates in a panel entitled “A Closer Look at Section 965 Campaigns” at D.C. Bar Taxation Community Tax Audits and Litigation Series. Description: Under the TCJA, Section 965 requires that US shareholders, including individuals, that directly or indirectly own at least 10% of
On November 17, 2020, Robert M. Russell participates in a panel entitled “View of International Tax-Part I Foreign Outbound” at 2020 AICPA Sophisticated Tax Conference. Description: This session is a high level review and update on certain hot topics in the International Tax arena including: – GILTI – FDII –