Yesterday, the U.S. Treasury Department issued final regulations (TD 10007, RIN 1545-BQ39) that identify certain syndicated conservation easement transactions (SCE) and substantially similar transactions as “listed transactions.” These SCE transactions must be reported on Form 8886, Reportable Transaction Disclosure Statement. In addition, material advisers to
The Financial Crimes Enforcement Network (FinCEN) today announced that it would extend the filing deadline for Reports of Foreign Bank and Financial Account (FBARs Form FinCEN 114) for people impacted by recent natural disasters in the United States, including Hurricane Helene, Hurricane Debby, Hurricane Beryl,
The Internal Revenue Service announced this week yet another way for taxpayers to address incorrect Employee Retention Credit (ERC) claims. The agency announced it is opening a “supplemental claim process” to help third-party payers (TPPs) and their clients resolve incorrect claims for the ERCs. This
Kostelanetz LLP Partner Megan L. Brackney is calling for an end to IRS foreign gift penalties, arguing that the current law is inefficient and punitive to lower- and middle-income taxpayers with foreign relatives. In an op-ed for Bloomberg Tax, Ms. Brackney addresses concerns raised by
In an August 24, 2024 decision, Varian Medical Systems Inc. v. Commissioner (Varian), the Tax Court offered a first view of how it will analyze challenges to Treasury regulations after the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo (Loper Bright). Loper Bright reversed
NEW YORK (September 4, 2024) — Kostelanetz LLP has been recognized by International Tax Review/World Tax as a top-tier firm for tax controversy in the publication’s 2025 rankings guide. Additionally, four of the firm’s partners have been recognized as “Highly Regarded” tax controversy practitioners. Both the New York
Kostelanetz partner Megan L. Brackney has been selected Chair-Elect of the American Bar Association (ABA) Section of Taxation for 2025-2026. The election of new Officers and Council Directors was held on August 2, 2024, at the American Bar Association’s 2024 Annual meeting in Chicago.
The Wall Street Journal quoted Caroline D. Ciraolo in an article titled “You Haven’t Filed Your Tax Returns in Years? The IRS is Coming,” published August 11, 2024. The article discusses the Internal Revenue Service’s focus on taxpayers earning more than $400,000 a year and discusses
NEW YORK (August 16, 2024) — Best Lawyers in America® has selected Kostelanetz LLP partners Caroline D. Ciraolo and Bryan C. Skarlatos for one of the ranking agency’s highest honors, naming both as a “Lawyer of the Year” for 2025. Caroline has been recognized as
Service Hopes Taxpayers Will Take a Second Look at Paid Claims The Internal Revenue Service (IRS) today announced the temporary reopening of the Voluntary Disclosure Program (VDP) for potentially erroneous Employee Retention Credit (ERC) claims. Participation in the VDP allows businesses to repay improper ERC
