On February 3, 2022, Caroline D. Ciraolo participates in the “Audits and Tax Controversy Panel” for the Florida Tax Institute.

Description: The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions. The reviews are expected to include the individual tax return of the sophisticated taxpayer as well as related partnerships, foundations, trusts, retirement plans, and other business structures. In the past year, the IRS also reaffirmed its interest in cross border activities with the announcement of three new campaigns targeting Nonresident Aliens who receive rental income from U.S. real property; FIRPTA compliance in connection with the withholding of tax and reporting obligations on the disposition of U.S. real property interests; and the U.S. activities of financial service entities and whether foreign investors participating in “inbound” lending transactions were engaged in a U.S. trade or business and generated income effectively connected with a U.S.-situs lending trade or business. The panel discusses these and other current developments and their implications for high wealth foreign and domestic taxpayers.

Speakers:

• Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP, Washington DC
• Carol Madison, IRS
• Fred Murray [Moderator], IRS
• Deborah Palacheck, IRS
• Clifford Scherwinski, IRS
• Steven Toscher, Hochman Salkin Toscher Perez P.C.

Click here for more information and to register.