TaxNotes quoted Caroline D. Ciraolo on the U.S. Sentencing Commission’s latest amendments to the U.S. Sentencing Guidelines, scheduled to take effect (absent congressional intervention) on November 1, 2024. From the article: “Although she said the acquitted conduct amendment from the commission has been “a long
Taxpayers Could Face Penalties, Interest, and Audits If Claims Are Found to Be Erroneous The Internal Revenue Service (IRS) is stepping up its rhetoric regarding potentially fraudulent Employee Retention Credit (ERC) claims, urging businesses to withdraw erroneous claims before the IRS reviews them and issues
Before the end of the U.S. Supreme Court’s term in June, the Court issued a landmark decision in SEC v. Jarkesy, et al., holding that the Seventh Amendment entitles a defendant to a jury trial when the U.S. Securities and Exchange Commission (“SEC”) pursues civil
Three Partners Also Named Leading Lawyers for High-Net-Worth Private Clients NEW YORK (July 22, 2024) — Kostelanetz LLP has been recognized by Chambers and Partners as a top-tier, Band 1 firm for high-net-worth private tax clients in its 2024 High Net Worth (HNW) Guide. In addition to the firm’s
TaxNotes quoted Andrew Weiner in an article titled “Supreme Court Opens Door to APA Challenges of Older Tax Regs,” published July 2, 2024. The article covers a recent Supreme Court holding in Corner Post Inc. v. Federal Reserve, a nontax case, that the six-year time bar
On July 8, 2024, the ABA Sections of Taxation and Real Property, Trust and Estate submitted comments on the proposed regulations under Internal Revenue Code (IRC) §§ 643(i), 679, 6039F, 6048, and 6677 regarding transactions with foreign trusts and information reporting on transactions with foreign
Michael Sardar was quoted in a July 5, 2024, MarketWatch article titled “What it’s like to be audited by the bigger, better-funded IRS. ‘They are pushing harder now.’” From the article: “With the IRS stepping up enforcement on upper-income taxpayers, Michael Sardar, a partner handling
On July 2, the IRS published proposed regulations providing that the IRS will assess as an underpayment of tax the interest paid to taxpayers on erroneous refunds of the employee retention credit (“ERC”), as well as other employment tax credits, such as the paid sick
On June 28, 2024, transgender activists, legal advocates, and currently unhoused transgender New Yorkers attended a press conference at Foley Square, regarding New York City’s obligation to provide transgender and gender nonconforming (“TGNC”) affirming shelter to unhoused New Yorkers. In a 2021 settlement resolving Mariah Lopez v.
Over the years, the circuits have split on how to interpret the statute of limitations for bringing a facial challenge to a regulation or other agency action under the Administrative Procedure Act (“APA”). Yesterday, in Corner Post, Inc. v. Board of Governors of the Federal
