More than four years ago, the Internal Revenue Service (“IRS”) expressed serious concern about monetized installment sales that, through the use of an intermediary and an installment note, purport to defer recognition of gain and income tax due on the sale of appreciated assets despite the seller’s effective, immediate receipt
On Tuesday, September 5th, 2023, Caroline D. Ciraolo presents a keynote address titled “The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement” at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge. Date: 8:00am BST (U.K. Time) on Tuesday September 5th, 2023. A full
On August 29, 2023, Don Fort, Director of Investigations at Kostelanetz LLP, will participate in an interview with IRS-CI Chief Jim Lee titled “IRS Enforcement Priorities” at the Summer Tax Summit presented by the St. Louis Chapter of the Federal Bar Association in St. Louis, MO. CLE credit is offered
On July 24, 2023, the IRS announced a major policy change, ending the decades-long practice of IRS revenue officers making unannounced visits to taxpayers’ homes and businesses. The surprise visits will be replaced with mailed letters to schedule face-to-face meetings. If a taxpayer does not respond to remote IRS contacts,
On Tuesday, September 5th, 2023, Caroline D. Ciraolo chairs a plenary workshop at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge. The workshop is titled “Aiding, abetting, and assisting – the facilitation of Tax Crimes” and is one of many sessions in the symposium. Date: 4:15pm
On August 15th, 2023, Caroline Ciraolo participates in a webinar panel titled “IRS Penalty Policy and Practice” as part of a webinar series titled “Transforming Tax Administration” presented by Center for Taxpayer Rights. Description: Center for Taxpayer Rights presents a series of webinars from March 23, 2023 through August 31,
Megan Brackney, Caroline Ciraolo, and Bryan Skarlatos Also Named Leading Lawyers NEW YORK (July 25, 2023) — Kostelanetz LLP and three attorneys have been recognized by Chambers and Partners as a top-tier U.S. law firm in its 2023 High Net Worth (HNW) Guide under the category of Tax: Private Client. In addition to
Caroline Ciraolo Selected As “Leading Lawyer” Kostelanetz LLP has been recognized for 2023 as a leading tax controversy firm by The Legal 500, and Caroline Ciraolo has been recognized as a “Leading Lawyer” by the independent legal rankings agency. In selecting Kostelanetz for recognition in its “US Taxes: Contentious” category, The Legal 500
The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60 participants engaging in a ”[h]igh-dollar
