By Megan L. Brackney Procedurally Taxing January 7, 2020 Reasonable Cause For all of the foreign information return penalties, reasonable cause is a defense. See I.R.C. §§ 6038, 6038A(d)(3), 6038D(g), 6039F(c)(2), 6677(d); Treas. Reg. § 1.6038-2(k)(3)(ii). The IRS applies the same standards for reasonable cause for failure to file income tax returns under I.R.C. §
NEW YORK (Jan. 06, 2020) — Kostelanetz & Fink is pleased to announce that Christopher M. Ferguson has been named a partner in the firm. Mr. Ferguson joined Kostelanetz & Fink’s New York office in 2003 and is a key member of K&F’s team with
By Megan L. Brackney Procedurally Taxing January 6, 2020 The IRS has been assessing more and more foreign information return penalties on taxpayers. It is difficult to find statistics on this point, as the IRS’s reports on tax penalties lump all “nonreturn” penalties into one category, which
In part one of a two-part interview, James Creech and Caroline Ciraolo discuss working at a tax controversies law firm, involvement in the Tax Section, and the Department of Justice Swiss Bank Program. Click here for Podcast Click here for Part Two
By Eric Smith The CPA Journal December 2019 Edition Thanks to legalized sports gambling, U.S. casinos generated a record amount of gaming revenue in 2018. As might be expected, it is becoming increasingly common for individuals to have questions regarding the taxation of gambling income and
Common errors include neglecting to report all taxable income or valuable deductions and credits Even with the increasingly widespread use of sophisticated tax-preparation software, it’s easy to make costly errors, omissions or both. In the dazzlingly complex world of income taxes, however, amending a return
By Caroline Rule ABA Section of Litigation, Criminal Litigation Committee December 5, 2019 Always request a DOJ Tax Division conference as soon as it appears that your client may face federal criminal tax charges. Suppose that you have a client who can afford for you to
Bryan C. Skarlatos participated on the panel “The Continuing Role of the Fifth Amendment Protections in Tax Enforcement” at the 36th Annual National Institute on Criminal Tax Fraud/9th Annual National Institute on Tax Controversy in Las Vegas, NV. The Fifth Amendment continues to be vital
Course Description This course will explore foreign asset reporting on Form 8938, which will focus on issues that can be traps for the unwary. This includes differences between foreign account reporting on Form 8938 versus the FBAR, asset valuation issues that impact certain classes of
The Top 100 Most Influential People – The thought leaders and change-makers who are shaping accounting One million tax practitioners: That’s how many Sid Kess has taught, and it would be enough to justify his influence — but beyond being the pre-eminent educator in the
