On April 22, 2021, the IRS issued Rev. Proc. 2021-20, which allows the recipient of an original Paycheck Protection Program (PPP) loan (the taxpayer) to deduct on its 2021 return expenses actually incurred in 2020 that were not previously allowed as deductions, so long as
In this first episode of the Financial Crimes – Dirty Money Stories podcast, Executive Vice President John Byrne of AML RightSource interviews K&F partner Jay Nanavati about his experience as both a prosecutor and a white collar defense attorney and how prosecutors often don’t have
Kostelanetz & Fink has joined with a group of Fortune 1000 General Counsel and more than 40 other law firms in The Alliance for Asian American Justice, a national pro bono initiative aimed at providing legal assistance to victims of anti-Asian violence or hate and
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 Crandall v. Commissioner (available here), in a win for taxpayers who have gone through the IRS’s offshore voluntary disclosure program (OVDP), the United States Tax Court held that the IRS was bound by the terms of a closing agreement and could not assert a
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’
The Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) recently showed their hands in their ongoing fight against tax noncompliance relating to cryptocurrency. The IRS is authorized by statute to issue John Doe administrative tax summonses to obtain information from third-parties regarding
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
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.
