Megan L. Brackney was quoted in a recent Tax Notes article entitled “Future Easement Charges Could Pivot on Economic Substance Questions,” published on January 29, 2021. Brackney discusses the potential future nature of syndicated easement charges and the legal issues facing easement promoters. The article
Robert M. Russell was quoted in a recent Tax Notes article entitled “LB&I Campaigns Aim to Advise Taxpayers, Not Increase Audits,” published on January 29, 2021. Russell observes that some LB&I compliance campaign treatment streams have raised questions from taxpayers. The article notes: Robert Russell
Caroline D. Ciraolo and Paul Butler were quoted in a recent Law360 article entitled “Pa. Judge’s Ruling in FBAR Case Could Add to Gov’t Arsenal,” published on January 25, 2021. Ciraolo and Butler discuss the implications of a recent court ruling on the imposition of
By Dan Davidson The CPA Journal December 2020/January 2021 Edition It is never pleasant when a client relationship ends on less than amicable terms. This is especially true when the relationship’s demise leads to litigation. A contract dispute that was recently litigated in bankruptcy court [In
By Eric Smith The CPA Journal December 2020/January 2021 Edition The liquidation of a partner’s entire partnership interest can take various forms, including payment made by the partnership to the retiring partner in complete redemption of the partner’s interest or a sale of such interest to
On December 11, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Notice 2020-1 (the Notice) which extends until April 15, 2022 the deadline to file Reports of Foreign Bank and Financial Accounts (FBARs) (FinCEN Form 114) for certain officers, employees, or agents of a U.S.
