Publications Archives - Page 7 of 26

OPR’s Star Chamber: Felons And The IRS’s Opaque Sanctions Process

By Megan L. Brackney and Daniel Q. Flesch Tax Notes Federal; Tax Notes State July 2021 Abstract: In this article, Brackney and Flesch examine the lack of transparency in the IRS Office of Professional Responsibility’s sanctions process and explore recently released administrative law judge and

What To Do When You’re Under The Government’s Microscope

By Claude M. Millman and Daniel Q. Flesch New York Nonprofit Media July 2021 Virtually no non-profit executive welcomes an audit or investigation with open arms. If you’ve dedicated your life to bettering the world by fighting for a social cause, you might react to

Penalties – The IRS’s New Practice Of Assessing Late-Filing Penalties On Timely Filed Substitute Forms 3520-A

By Caroline Rule and Jas Singh The Journal of Tax Practice & Procedure Summer 2021 Issue The IRS has begun systematically imposing late-filing penalties on substitute Forms 3520-A even when they have been filed on time. This new mistaken practice forces a taxpayer who does

The IRS Ramps Up Cryptocurrency Enforcement

By Caroline Rule and Daniel Q. Flesch The Journal of Tax Practice & Procedure Summer 2021 Issue At a Federal Bar Association conference in March of this year, Damon Rowe—Director of the Office of Fraud Enforcement at the IRS—announced a new initiative. Operation Hidden Treasure

Tax Controversies: Audits, Investigations, Trials (40th Edition)

By Robert S. Fink LexisNexis 40th Edition 2021 The 40th edition of “Tax Controversies: Audits, Investigations, Trials” has been published and is available on Lexis-Nexis. Authored by Kostelanetz & Fink co-founder Robert S. Fink and the attorneys of Kostelanetz & Fink, Tax Controversies is the recognized guide

Navigating the IRS’s Self-Dealing Rules for Private Foundations

By Usman Mohammad and Emma Westerhof The CPA Journal, Tax Practice & Procedure Column April/May 2021 Issue The Donald J. Trump Foundation was undone by alleged acts of self-dealing involving its namesake, Donald J. Trump, who also allegedly used the foundation to promote his candidacy

Employers Beware! Payroll Tax Violations Come With A Very Heavy Price

By Caroline D. Ciraolo The Federal Lawyer, Federal Bar Association May/June 2021 Issue In fiscal year 2020, the Internal Revenue Service (IRS) was responsible for more than 96 percent of the gross revenue received on behalf of the United States. Employment taxes, including federal income tax

The IRS Is Underfunded, But It Needs More Than Cash To Stop Tax Cheats

By John D. (Don) Fort Washington Post May 6, 2021 It’s been said that the most feared three letters in the United States are “IRS.” Even my own heart has skipped a few beats on the occasions I have received routine correspondence from the agency,

ABA Tax Section Important Civil Developments May 2021 Report

By Stephen A. Josey, Russell A.S. Wirth, et al. American Bar Association, Tax Section Civil & Criminal Tax Penalties Committee May 2021 Meeting The ABA Tax Section meets three time a year, and at each meeting the subcommittees of the Civil & Criminal Tax Penalties

The IRS’s Assessment Of Penalties On Substitute Forms 3520-A

By Megan L. Brackney Tax Notes International, Volume 102 Issue 3 Tax Notes Federal, Volume 171 Issue 3 April 19, 2021 In recent months, we have seen several clients being heavily penalized for purportedly late filing Form 3520-A, “Annual Information Return of Foreign Trust With