Caroline D. Ciraolo was quoted in a recent Bloomberg Tax article titled “IRS Goes After Wealthy Tax Scofflaws as More Complex Cases Brew,” published July 18th, 2023. The article discusses recent Internal Revenue Service efforts to bolster their enforcement capabilities as enforcement issues increase in complexity.
Caroline Ciraolo Selected As “Leading Lawyer” Kostelanetz LLP has been recognized for 2023 as a leading tax controversy firm by The Legal 500, and Caroline Ciraolo has been recognized as a “Leading Lawyer” by the independent legal rankings agency. In selecting Kostelanetz for recognition in its “US Taxes:
The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60
In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et
As reported in our last news alert, the IRS is moving aggressively to investigate Malta Pension Plans. This is after naming Malta Pension Plans to the IRS’s Dirty Dozen (its annual list of abusive transactions), issuing a Competent Authority Arrangement walking back the tax benefits
By Garrett L. Brodeur Tax Notes Federal July 3, 2023 In a recent Letter to the Editor, Garrett L. Brodeur noted that several recent informal guidance documents on the tax treatment of cryptoassets suggest that the IRS is striving to provide meaningful direction, even under
Malta Pension Plan arrangements under the United States-Malta Income Tax Treaty are a top enforcement priority of the IRS, finding their way onto the annual Dirty Dozen list. Yesterday, the IRS intensified its efforts as Special Agents from IRS Criminal Investigation (IRS-CI) descended on numerous
The New York State Bar Association (NYSBA) Tax Section published Report No. 1478 on June 18, 2023 to provide comments on the IRS’s recent proposal (in Notice 2023-27) to tax certain NFTs as “collectibles” under section 408 of the Internal Revenue Code. As a member
Michael Sardar was quoted in a recent article in Yahoo Finance entitled “IRS gets major power to request private tax info after Supreme Court decision,” published on June 11, 2023. The article discusses the ramifications of Polselli v. International Revenue Service on taxpayer and third-party privacy.
