Robert Russell Participates In A Webinar Entitled "IRS & Treasury Panel: Partnership Reporting (Inbound)" For The ABA
2020-08-18
The American Bar Association (ABA), the American Institute of Certified Public Accountants (AICPA), and the Tax Executives Institute (TEI), along with the U.S. Treasury Department and the IRS, held a two-part series of webinars to discuss the proposed redesigned partnership form for tax year 2021 (filing season 2022). Robert Russell participated in part two, on August 18, 2020.
The proposed form was designed to provide greater clarity for partners on how to compute their U.S. income tax liability with respect to items of international tax relevance, including claiming deductions and credits. Leaders from ABA, AICPA, TEI and the government facilitated an hour-long panel discussion which included an overview of the new forms, what the government was trying to accomplish in designing the forms, and a question and answer period.
The inbound (generally) components of the new forms:
• Base Erosion Anti-Abuse Tax
• Income effectively connected with a U.S. trade or business
• Fixed, determinable, annual, periodical income
• Gain or loss of foreign persons from sale or exchange of certain partnership interests
• Treatment of dividend equivalent payments
Panelists included:
Lori Hellkamp, Jones Day, Washington, DC
Robert Russell, Kostelanetz & Fink, LLP, Washington, DC (Moderator)
Blake Udall, GoDaddy Inc., Scottsdale, AZ
Shiukay Hung, Tishman Speyer, New York, NY
John Hinding – Director, Cross Border Activities, IRS Large Business and International
Margaret (Peg) O’Connor – Director, Treaties (Former Deputy Associate Chief Counsel – International), IRS Large Business and International
Cindy Kim – Program Manager, Cross Border Activities, IRS Large Business and International
Karen Cate – Senior Advisor –Office of Associate Chief Counsel International
Peter Merkel – Branch Chief– Office of Associate Chief Counsel International
Erika Nijenhuis – Senior Counsel, US Department of Treasury – Office of Tax Policy
Kamela Nelan – Attorney-Advisor, US Department of Treasury – Office of Tax Policy

Bryan C. Skarlatos Presents A Webinar Entitled “Ethical And Penalty Standards For Taking Positions On Tax Returns And Advising Clients” At The 51st Annual Sidney Kess New York Estate, Tax, & Financial Planning Conference
2020-09-23
On September 23, 2020, Bryan C. Skarlatos presented major new developments in tax controversies and ethical considerations with Ernest Patrick Smith.
The 51st Annual Sidney Kess New York Estate, Tax, & Financial Planning Conference included discussion of estate, tax, and financial planning opportunities while taking into account the current state of the economy and implications of the outcomes of the upcoming November elections.
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Bryan C. Skarlatos Interviews Don Fort, Chief, IRS CID On "Current Developments In The Internal Revenue Service Criminal Investigation Division" For The CPA Academy
2020-09-24
On September 24, 2020, Don Fort, the Chief of the IRS Criminal Investigation Division, discussed with Bryan Skarlatos current IRS initiatives and priorities including use of data to assist in criminal tax investigations, international cooperation among countries in tax fraud prosecutions, the use of crypto currency in tax crimes and the IRS role in investigating and prosecuting COVID-related stimulus fraud.
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Caroline Ciraolo Interviews Members Of The U.S. Department Of Justice’s Tax Division During ABA’s Virtual 2020 Fall Tax Meeting
2020-09-29
This panel is part of ABA’s Virtual 2020 Fall Tax Meeting, which consists of more than 40 CLE programs, a networking reception, and two plenary sessions over four days. Participants learn from and meet with the country’s leading tax attorneys and government officials, and discuss the latest federal, state, and local tax policies and more.
Civil & Criminal Tax Penalties
2:30PM: Update: Tax Division, U.S. Department of Justice.
Moderator: Caroline Ciraolo, Kostelanetz & Fink, LLP, Washington, DC
Panelists: Richard E. Zuckerman, Principal Deputy Assistant Attorney General, Tax Division, U.S. Department of Justice, Washington, DC; Josh Wu, Deputy Assistant Attorney General (Appellate), Tax Division, U.S. Department of Justice, Washington, DC
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Caroline D. Ciraolo Chairs The Civil And Criminal Tax Penalties Committee Virtual Fall Meeting For The American Bar Association’s Section Of Taxation
2020-09-29
ABA’s Virtual 2020 Fall Tax Meeting consists of more than 40 CLE programs, a networking reception, and two plenary sessions over four days. Participants learn from and meet with the country’s leading tax attorneys and government officials, and discuss the latest federal, state, and local tax policies and more.
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Megan L. Brackney Participates In A Panel Entitled "Who Is A Return Preparer Under 6694?" At The ABA's 2020 Fall Tax Meeting
2020-10-01
On October 1, 2020, Megan L. Brackney participates in a panel entitled “Who is a Return Preparer Under 6694?” at the ABA’s 2020 Fall Tax Meeting, as part of its programming on Standards of Tax Practice.
Who is a Return Preparer Under 6694? This once sleepy backwater of the Code is now becoming an important tool for enforcement. This 50-minute panel discusses the definition of “return preparer” under Sec. 6694, and how the government is using Sec. 6694 to impose penalties and seek injunctions against return preparers whose advice does not meet its standards for return positions.
Introduction By: Logan Abernathy, Sirote & Permutt, PC
Moderator: Alexandra Minkovich, Baker McKenzie
Panelists: James C. Fee, Senior Level Counsel, IRS Office of Division Counsel (LB&I) (Invited); Megan L. Brackney, Kostelanetz & Fink, LLP; Matthew S. Cooper, Deloitte Tax LLP
Co-Sponsored by: Court Practice and Procedure & Civil Criminal Tax Penalties
The ABA’s 2020 Fall Tax Meeting was held virtually on September 29-October 2, 2020. Click here for more information

Megan L. Brackney Presents A Webinar Entitled “Reporting Cash Received In A Business: Form 8300 Requirements And Penalties” On CPA Academy
2020-10-08
On October 8, 2020, Megan L. Brackney discusses the requirements for filing Forms 8300 and sending payee statements, the penalties for non-compliance, and defenses to penalties.
Course objectives included: identifying transactions that must be reported on Form 8300; reviewing Form 8300 preparation; identifying the penalties or failure to file Form 8300 and to issue payee statements and defenses to penalties; discussing criminal penalties for Form 8300 violations; developing best practices to assist clients with Form 8300 compliance.
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Robert M. Russell Participates In A Panel Entitled “Federal And State Tax Controversy In A Big Data World” As Part Of The 75th Annual TEI Conference
2020-10-27
Robert Russell participates in a panel entitled “Federal and State Tax Controversy in a Big Data World” as part of the 75th annual Tax Executives Institute (TEI) Conference on October 27, 2020.
The panel explores the evolving use of “Big Data” in tax controversies. Practitioners share their experiences with employing data analytics to bolster taxpayers’ positions during audits. The panelists also discuss recent developments in taxing authorities’ enforcement in this area.
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Caroline D. Ciraolo Presents The “Criminal Tax Update” At American Academy of Attorney-CPAs Fall Meeting Webinar Series
2020-11-10 14:00 - 15:15 (America/New_York)
On November 10, 2020, Caroline D. Ciraolo presents the “Criminal Tax Update” At American Academy of Attorney-CPAs Fall Meeting Webinar Series.
Description: On October 15, 2020, the U.S. Department of Justice announced an indictment in the largest ever tax fraud investigation. This is among a series of recent press releases involving indictments, guilty pleas, convictions, and sentencings for criminal tax violations ranging from failure to file tax returns, filing false returns, tax evasion, and conspiracies to defraud the IRS. These announcements make it clear that IRS – Criminal Investigation and the Justice Department are actively pursuing those who willfully seek to violate the internal revenue laws. This program reviews the current landscape of criminal tax enforcement, government priorities, recent prosecutions, and best practices for those practitioners whose clients find themselves in entangled in a criminal tax investigation as a witness, subject or target.
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Megan L. Brackney Participates In A Panel Entitled “Problems Facing Taxpayers With Foreign Information Return Penalties (Statute of Limitations, Jurisdictional Concerns, Flora, etc.)” At The University of San Diego 16th Annual USD School of Law-Procopio International Tax Law Institute via Zoom
2020-11-12 16:00 - 17:00
On November 12, 2020, Megan L. Brackney participates in a panel entitled “Problems Facing Taxpayers with Foreign Information Return Penalties (Statute of Limitations, Jurisdictional Concerns, Flora, etc.)” at The University of San Diego 16th Annual USD School of Law-Procopio International Tax Law Institute via Zoom.
Panel information: The IRS continues to assess penalties for late filing foreign information returns, such as the Form 8938 (Report of Specified Foreign Assets or the Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts). The IRS claims these penalties are “assessable” and ordinarily not subject to the jurisdiction of the U.S. Tax Court; it can thus be very difficult for taxpayers, who have to pay before bringing a refund claim, to receive judicial review. There are issues of time limits and procedures required by both the taxpayer and the government. This panel discusses a few common foreign information returns, the penalties for non-filing or filing incomplete forms, defenses to penalties, and the procedures that are available for taxpayers seeking review of the assessments, including IRS Appeals, refund litigation, Collection Due Process, and the availability of injunctive and declaratory relief.
Panelists: Robert Horowitz, Esq. – Hochman Salkin Toscher Perez P.C. (Formerly DOJ, Tax Division), Megan L. Brackney, Esq. – Kostelanetz & Fink, LLP, Patrick W. Martin, Esq. – Procopio
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Caroline D. Ciraolo And Robert M. Russell Participate In A Panel Entitled “IRS Enforcement Priorities” At 2020 AICPA Sophisticated Tax Conference
2020-11-16 16:20 - 17:10
On November 16, 2020, Caroline D. Ciraolo and Robert M. Russell participate in a panel entitled “IRS Enforcement Priorities” at 2020 AICPA Sophisticated Tax Conference.
Description: This presentation addresses current IRS civil and criminal enforcement domestic and international priorities and share best practices in representing clients facing IRS enforcement efforts.
Learning Objectives:

Understanding current IRS civil and criminal enforcement priorities
Learning “best practices” in addressing IRS enforcement efforts

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Robert M. Russell Participates In A Panel Entitled “View Of International Tax-Part I Foreign Outbound” At 2020 AICPA Sophisticated Tax Conference
2020-11-17 12:40 - 13:30
On November 17, 2020, Robert M. Russell participates in a panel entitled “View of International Tax-Part I Foreign Outbound” at 2020 AICPA Sophisticated Tax Conference.
Description: This session is a high level review and update on certain hot topics in the International Tax arena including:
– GILTI
– FDII
– Foreign Tax Credits, and
– Taxation of the Digital Economy
Learning Objectives:

Identify where there may be GILTI, FDII or a Foreign tax credit benefit
Understand impact of recent regulations on calculating GILTI, FDII and Foreign Tax Credits

Speakers:
Robert Russell, CPA, J.D., LL.M. Taxation, Counsel, Kostelanetz & Fink, LLP
Chaya Siegfried, CPA, MST, Lead, International Business Tax Services, Withum

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Claude M. Millman Participates In A Panel Entitled “What To Know About Doing Business In New York Post COVID” At City And State’s 2020 Virtual Government Procurement Conference
2020-11-17 13:40 - 14:40
On November 17, Claude M. Millman joins a panel of procurement professionals, including New York government officials, in a discussion of what New York businesses and non-profits will need to do to navigate the city and state’s procurement systems in a post-COVID world, at City and State’s 2020 Virtual Government Procurement Conference, featuring a keynote speech by New York City’s Chief Procurement Officer. Registration is free at https://www.cityandstateny.com/events/virtual-government-procurement-conference.
Description: Citing the high costs of doing business in New York City and the devastating impact the COVID-19 impact aspects of procurement are distinct to New York in terms of laws, taxes and MWBE procurement. This panel provides an inside look at the New York procurement process and prepare you to navigate the system in a post-COVID world including strategies effective at addressing potential challenges including the possibility of a second wave, tips to win the bidding process and also explain the complexity of RFPs, plus hear what NY government entities want from potential contractors.
Presenters:
Annie McDonough, Tech Reporter, City & State NY (moderator)
Rachel Miller, Associate Commissioner and Agency Chief Contracting Officer, NYC Administration for Children’s Services
Mersida Ibric, Deputy Commissioner, NYC Office of Citywide Procurement
Kristin Malek, Senior Manager, Supplier Diversity, CDW
Claude M. Millman, Partner, Kostelanetz & Fink, LLP
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Caroline D. Ciraolo And Jay R. Nanavati Participate In A Panel Entitled “Current AML and OFAC Compliance Issues” At Bahamas Financial Services Board Industry Development Webinar Series
2020-11-17 14:30 - 15:30
On November 17, 2020, Caroline D. Ciraolo and Jay R. Nanavati participate in a panel entitled “Current AML and OFAC Compliance Issues” at Bahamas Financial Services Board Industry Development Webinar Series.
Description: Join the Bahamas Financial Services Board, in collaboration with AlixPartners, a global consulting firm, and Kostelanetz & Fink, a U.S. law firm, for a webinar discussing current compliance issues as well as the results of AlixPartners’ recent AML and OFAC/Sanctions survey.
The presentation covers the following main topics:

AML & Sanctions Enforcement Panorama
Stakeholder Views on AML & Sanctions Compliance – Financial Institutions, External Counsel and Shareholders/Investors
De-risking as a Risk Mitigation Tool
Culture of Compliance as a way to Mitigate Financial Crime Risk
Investment in, and Creative new ways to, Fight Financial Crime

Presenters:
AlixPartners:

Rich Kando, Managing Director
Isaac Fisboin, Director
Gautam Sachdev, Director

Kostelanetz & Fink:

Caroline Ciraolo, Partner
Jay Nanavati, Partner

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Bryan C. Skarlatos Chairs An Ethics Webinar Entitled, "Ethical Issues For Tax Practitioners: Good Tax Planning, Aggressive Tax Advice, Or Criminal Tax Evasion" At The NYU School Of Professional Studies 79th Virtual Institute On Federal Taxation
2020-11-18 11:30 - 13:30
On November 18, 2020, Bryan C. Skarlatos chairs an ethics webinar entitled, “Ethical Issues for Tax Practitioners: Good Tax Planning, Aggressive Tax Advice, or Criminal Tax Evasion” at The NYU School Of Professional Studies 79th Virtual Institute On Federal Taxation.
Description: Is that payment a gift or compensation for services? Is the expenditure a deductable repair or a capital improvement? Is the income ordinary income or capital gain? How sure do you have to be before you advise a client on issues such as these? Can you rely on what the client tells you or do you have to audit the client’s information? When can you, as the practitioner, get caught up in the client’s wrongdoing? Responsible tax practitioners must know how to approach these questions. This panel provides an up-date on the ethical, civil penalty and criminal standards governing practitioners who give tax advice and how those standards apply in everyday practice.
Panelists:
Ethics Chair: Bryan C. Skarlatos, Esq., Partner, Kostelanetz & Fink, New York, NY
Speakers:
Miriam L. Fisher, Esq., Global Chair of Tax Controversy, Latham & Watkins, Washington, DC
Christopher S. Rizek, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
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Caroline D. Ciraolo Moderates A Discussion With Daniel N. Price, IRS Office Of Chief Counsel, Entitled “Coming In From The Cold – Risks And Rewards Of The Revised IRS Voluntary Disclosure Practice” At ABA Tax Section Civil & Criminal Tax Penalties Committee
2020-11-18 13:00 - 14:35
On November 18, 2020, Caroline D. Ciraolo moderates a discussion with Daniel N. Price, IRS Office of Chief Counsel, entitled “Coming in from the Cold – Risks and Rewards of the Revised IRS Voluntary Disclosure Practice” at ABA Tax Section Civil & Criminal Tax Penalties Committee.
Description: In November 2018, the IRS revised its long-standing voluntary disclosure practice. In April 2020, the IRS released an updated Form 14457,Voluntary Disclosure Practice Preclearance Request and Application, with detailed instructions, offering valuable insight into the internal processing of a voluntary disclosures, eligibility, and revocation of preliminary approvals. With this information in hand, practitioners are trying to determine whether a voluntary disclosure is best for their clients, and the IRS is here to help! Dan Price is a senior attorney with IRS Office of Chief Counsel and a member of the team that drafted the voluntary disclosure guidance. Dan discusses his history with voluntary disclosures, what led to the new penalty framework, eligibility and compliance under the revised practice, and some of the issues the IRS is considering for future guidance. Following the discussion, Dan takes questions from the audience.

Speakers:
Caroline D. Ciraolo, Kostelanetz & Fink, LLP (Moderator)
Daniel N. Price, IRS Office of Chief Counsel
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Michael Sardar Participates In A Panel Entitled “What Does The IRS Have? How To Make A Freedom Of Information Act (FOIA) Request And Why” At The IRS Representation Conference
2020-11-19 12:30 - 13:30
On November 19, 2020, Michael Sardar participates in a panel entitled “What Does the IRS Have? How to Make a Freedom of Information Act (FOIA) Request and Why” as part of the IRS Representation Conference’s Low-Income Taxpayer Clinic Workshop.
Panel information: Maybe the client was audited, has been assessed a trust fund recovery penalty, or is the subject of a criminal investigation after dealing with the IRS Collections Division. There many reasons why it would be really helpful to have a look at what the IRS file says about the taxpayer and their situation. This panel discusses the mechanics of drafting and filing a request under the Freedom of Information Act, including what records are available, what records might be withheld pursuant to various exemptions, and how best to make use of that information to help your taxpayer.
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Caroline D. Ciraolo Participates In A Panel Entitled “Avoiding A Criminal Referral For Employment Tax Violations” At The IRS Representation Conference
2020-11-19 14:45 - 15:45
On November 19, 2020, Caroline D. Ciraolo participates in a panel entitled “Avoiding a Criminal Referral for Employment Tax Violations” as part of the IRS Representation Conference’s Low-Income Taxpayer Clinic Workshop.
Panel information: Statistically, nearly 80% of small businesses fail, often owing payroll taxes. Many of these situations are resolved by the IRS with its civil enforcement tools, but some are referred to IRS Criminal Investigation. So, what makes one case a civil matter and another case ripe for criminal investigation and prosecution? The panel discusses the statutory framework, applicable rules and regulations, and steps employers can take if they find themselves falling behind on their employment tax obligations in an effort to avoid a criminal referral.
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Megan L. Brackney Participates In A Panel Entitled “Partnership Audit Rules” At The NYU 79th Virtual Institute On Federal Taxation
2020-11-19 16:00 - 18:00
On November 19, 2020, Megan L. Brackney participates in a panel entitled “Partnership Audit Rules” as part of the NYU 79th Virtual Institute on Federal Taxation.
Panel information: UPDATE ON THE CENTRALIZED PARTNERSHIP AUDIT RULES: ARE YOU AND YOUR CLIENTS READY? Now that entities taxed as partnerships and their tax advisors have had three years to understand and put into place procedures as well as revisions to outstanding partnership and LLC operating agreements to adapt to the new partnership audit rule regime, the focus now turns to how tax audits, appeals, settlements, litigation, and appeals of adverse judicial determinations will work in “real time.” The co-chairs address problems associated with elections-out, understatement modifications, push-outs and pull-ins, as well as how partners can protect themselves from the partnership representative’s unilateral authority to settle out all partnership issues. Continuing applicability of the TEFRA audit rules for tax years beginning on or before 2017 also are discussed.
Co-Chairs: Jerald David August, Esq., Partner, Fox Rothschild, Philadelphia, PA Megan L. Brackney, Esq., Partner, Kostelanetz & Fink, New York, NY
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Caroline D. Ciraolo Interviews IRS Chief Counsel Michael Desmond During The IRS Enforcement Update Panel At The IRS Representation Conference
2020-11-20 08:40 - 10:40
On November 20, 2020, Caroline D. Ciraolo interviews IRS Chief Counsel Michael Desmond during the IRS Enforcement Update panel at the IRS Representation Conference.
Panel information: Voluntary compliance and enforcement of the tax laws are at the heart of our tax system. Over the past several years, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers report and pay the correct amount of tax. Ms. Ciraolo’s interview provides an update on new developments at the IRS, Office of Chief Counsel.
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Bryan C. Skarlatos Moderates A Panel Entitled “IRS Enforcement Update” At The IRS Representation Conference
2020-11-20 08:40 - 10:40
On November 20, 2020, Bryan C. Skarlatos moderates a panel entitled “IRS Enforcement Update” as part of the IRS Representation Conference.
Panel information: Voluntary compliance and enforcement of the tax laws are at the heart of our tax system. Over the past several years, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers report and pay the correct amount of tax. The panel providea an update on new developments at the IRS.

SB/SE: Eric Hylton, Commissioner, SB/SE Division, Internal Revenue Service, interviewed by Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT
Collections: Eric Hylton, Commissioner, SB/SE Division, Internal Revenue Service, interviewed by Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Criminal: James Lee, Chief, Criminal Investigation, Internal Revenue Service, interviewed by Kathy Keneally, Esq. Jones Day, New York, NY
Office of Chief Counsel: Michael Desmond, Chief Counsel, Internal Revenue Service, Washington, DC, interviewed by Caroline D. Ciraolo, Esq. Kostelanetz & Fink, LLP

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Megan L. Brackney Participates In A Panel Entitled “Dealing With The Undocumented Worker” At The IRS Representation Conference
2020-11-20 12:45 - 13:45
On November 20, 2020, Megan L. Brackney participates in a panel entitled “Dealing with the Undocumented Worker” as part of the IRS Representation Conference.
Panel information: Employers who choose to hire undocumented workers often do not understand the potential mess they have created for themselves and their workers. The panel unpacks the myriad issues these employers face, including employment taxes, labor violations, and immigration issues. The panel also discusses potential ways to clean up the situation before IRS initiates contact.
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Sharon L. McCarthy Participates In A Panel Entitled “Defenses To Tax Crimes: Attacking Willfulness” At The IRS Representation Conference
2020-11-20 15:00 - 16:00
On November 20, 2020, Sharon L. McCarthy participates in a panel entitled “Defenses to Tax Crimes: Attacking Willfulness” as part of the IRS Representation Conference.
Panel information: tax crimes are specific intent crimes—requiring the violation of a known legal duty. The panel explores when a potential mental impairment should be considered as a defense or as mitigation in sentencing.
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Bryan C. Skarlatos Participates In A Fireside Chat With The Commissioner Of The IRS, Charles P. Rettig Hosted By The NYU Law Graduate Tax Program
2020-11-23 15:00 - 16:00
On November 23, 2020, Bryan C. Skarlatos LLM ’91 participates in a fireside chat with the Commissioner of the IRS, Charles P. Rettig LLM ’82 hosted by the NYU Law Graduate Tax Program.
Description: This special conversation includes sharing reflections and experiences over a long career and is part of our ongoing virtual celebration of the Graduate Tax Program at 75 years.
Steven Dean, Director of the NYU School of Law Graduate Tax Program introduces the discussion.
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Don Fort Participates In A Panel Entitled "What Every Estate Planner and Tax Advisor Should Know About Criminal Tax and White Collar Crimes?" For The Hawaii State Bar Association
2020-12-01
On December 1, 2020, Don Fort participates in a webinar panel entitled “What Every Estate Planner and Tax Advisor Should Know About Criminal Tax and White Collar Crimes?” hosted by the Hawaii State Bar Association (HSBA).
The presentation addresses the HSBA’s Tax Section, Probate and Estate Planning (PEP) and Elder Law Sections, and International Law Section. Members of the Hawaii Society of CPAs are also invited to attend.
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Michael Sardar Presents “Nobody Is Perfect: How Sure Do You Need to Be When Taking a Position on a Return” At The 22nd Baruch College Estate, Tax, And Finance Planning Conference
2020-12-01 13:00 - 14:00
On December 1, 2020, Michael Sardar presents “Nobody Is Perfect: How Sure Do You Need to Be When Taking a Position on a Return” at the 22nd Baruch College Estate, Tax, and Finance Planning Conference.

Description:
This course covers the tax reporting standards applicable to taxpayers and practitioners and review when penalties can be imposed for tax return errors.

Learning Objectives:
Recognize what standards apply when the IRS determines whether or not to impose a penalty in connection with an erroneous position on a tax return
Demonstrate the difference between the reasonable basis, substantial authority, and more likely than not standards
Identify when can the practitioner be penalized for an error on a taxpayer’s return
Identify when, how, and why to make adequate disclosure of an uncertain tax position
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Megan L. Brackney Teaches A Course Entitled “Tax Penalties: Focus On IRS Enforcement Priorities” For CPA Academy
2020-12-02 11:00 - 12:00
On December 2, 2020, Megan L. Brackney teaches a course entitled “Tax Penalties: Focus on IRS Enforcement Priorities” for CPA Academy.
Course Description: This program will discuss the tax penalties that relate to the IRS’s current enforcement priorities, including trust fund recovery penalties, gross valuation misstatement penalties, and foreign asset reporting penalties.
Learning Objectives:

Recognize several types of tax penalties.
Identify the potential defenses to penalties, including the meaning of “reasonable cause” in these specific contexts.
Demonstrate the procedures for challenging these penalties.

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Robert M. Russell Participates In A Panel Entitled "A Closer Look At Section 965 Campaigns” At D.C. Bar Taxation Community Tax Audits And Litigation Series
2020-12-02 12:00 - 13:30
On December 2, 2020, Robert M. Russell participates in a panel entitled “A Closer Look at Section 965 Campaigns” at D.C. Bar Taxation Community Tax Audits and Litigation Series.
Description: Under the TCJA, Section 965 requires that US shareholders, including individuals, that directly or indirectly own at least 10% of the stock of a specified foreign corporation, include in gross income their share of the corporation’s accumulated deferred foreign income. Panelists will discuss how the IRS is approaching Section 965 compliance through the campaigns, methodologies for calculating and reporting tax under Section 965, privilege issues, and potential penalties for noncompliance.
Speakers:
Robert M. Russell, Kostelanetz & Fink, LLP
Orrin D. Byrd, Director Field Operations East LB&I Cross Border Activities (CBA)
Kathleen Saunders Gregor, Ropes & Gray LLP

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Don Fort Interviewed By Tom Temin On "Federal Drive With Tom Temin"
2020-12-03
On December 3, 2020, Don Fort discussed his new role as Director of Investigations at Kostelanetz & Fink and reflected on his nearly 30 years of experience at the IRS during his interview with Tom Temin.
On “Federal Drive with Tom Temin,” Tom Temin interviews federal executives and government contractors who provide analysis and insight on the many critical issues facing the Executive branch.
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Don Fort Participates In A Panel Entitled “Criminal Tax Update” At UNC School Of Law Tax Institute Speaker Series
2020-12-04 11:00 - 13:30
On December 4, 2020, Don Fort participates in a panel entitled “Criminal Tax Update” at UNC School of Law Tax Institute Speaker Series.
Description: New at UNC Law, the Tax Institute Speaker Series features tax practitioners and scholars from throughout the country who will address current developments in taxation. The Speaker Series offers periodic, short sessions (2-3 hours) with networking opportunities throughout the year.
Program sessions in the first installment of the Speaker Series on December 4, 2020 include:
Criminal Tax Update (11:00am-12:00pm)
Speakers:
Kevin Downing, Kevin Downing Law
Caryn Finley, U.S. Attorney’s Office
Don Fort, Kostelanetz & Fink
Justin Thornton, Law Offices of Justin Thornton
Ethical Issues Under the BBA Partnership Audit Regime (12:30pm-1:30pm)
Speaker:
Christopher S. Rizek, Caplin & Drysdale
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