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Supreme Court Case Offers Good Defense Against Trump IRS Audits

Can Tax Promoter Penalties be ‘Excessive Fines’ Under the Eighth Amendment?

DOJ's Tracing Rule for Pandemic Loan Fraud Is Untenable

Federal Tax Prosecutions Before and After Department of Justice Tax Division Is Eliminated

Ownership Without Intermediaries: Comparing Cryptocurrency to Bearer Instruments

Defending a Pandemic Fraud Prosecution

Considerations for Tax Return Preparers Outsourcing Overseas

Does Due Process Require More Than Refund Jurisdiction Over Tax Promoter Penalties?

Treasury Issues Proposed Regulations Amending Circular 230

Treasury Issues Proposed Regulations Amending Circular 230

Do Tax Promoter Penalties Trigger the Right to a Jury Trial After Jarkesy?

No Theft Loss Deduction for a Stolen Heart

Demystifying DeFi: Tax Compliance for Individuals Engaging In Decentralized Finance (DeFi) Transactions

CARES Act Fraud Enforcement Turns Five: A Look at the Last Five Years and the Next Five

Seeking Relief from SEC for Securities Industry Bars and Professional Suspensions

Twelve Angry Taxpayers: Why the Constitution Might Guarantee a Jury Trial for Accuracy and Fraud Penalties in Tax Cases after SEC v. Jarkesy

DOJ’s New Crypto Crime Guidance Muddies the Prosecutorial Waters

Theft Loss Deductions Under the Tax Cuts and Jobs Act of 2017

Claiming Residency in Puerto Rico May Spur More State-Based Tax Audits

Bloomberg Tax: How Tax Pros Can Shift from Government to Private Sector Work

IRS’s Enhanced Enforcement Efforts for Partnerships and High-Net-Worth Individuals

Basic Tax Reporting for Decedents and Estates

Corporate Transparency Act to Only Be Enforced Against Foreign Entities

Buckle Up: Navigating the Long Road of the BBA Partnership Audit

Advising Healthcare and Hospitality REITs through Increasing Scrutiny

Loper Bright: The Supreme Court’s New Standard for Challenging Tax Regulations

Forbes: Why Filing A Tax Return Is More Important Than Paying Tax

What’s in store for the World of Tax in 2025?

Kostelanetz Recaps 2024’s Biggest Stories in Tax

The New State of Administrative Law: Overview of the Potential Impact of Loper Bright and Corner Post on Tax Cases

Christopher Ferguson Quoted in Forbes on Ending of ERC Voluntary Disclosure Program

Last Call for the IRS’s ERC Voluntary Disclosure Program – Who Can and Should Participate?

Michael Sardar Quoted in Tax Notes on Proposed Foreign Trust and Gift Regulations

Wall Street Journal Quotes Bryan Skarlatos on IRS Case Against “Abusive-Trust Tax Shelter”

U.S. Treasury Issues Final Regulations Identifying Syndicated Conservation Easements as Abusive Tax Transactions

‘Draconian’ IRS Foreign Gift Penalties Serve No Practical Purpose

Megan Brackney Selected Chair-Elect of ABA Tax Section

Kostelanetz Partners Caroline Ciraolo and Bryan Skarlatos Honored with “Lawyer of the Year” Awards from Best Lawyers for 2025

TaxNotes Quotes Christopher Ferguson On Loper Bright And IRS Enforcement Actions Against ERC Promoters

TaxNotes Discusses Megan Brackney And Macdonald Norman’s Memo In Article On Jarkesy And Tax Fraud Penalties

‘Double Dip’ Dilemmas: The Rise And Risks Of Tax-Based Fixed Indemnity Plans

IRS Policy, Chevron Ruling May Prove ERC Claims Unsustainable

Joint DOJ/FTC Announcement Signals an Aggressive Approach in the Government’s Battle to Capture Off-Channel Communications

Supreme Court Defers Fundamental Constitutional Question in Upholding Tax on Foreign Business Income

Employee Retention Credit Compliance For Nonprofits

Usman Mohammad Quoted in Crain’s Article About Kostelanetz Pro Bono Litigation

FAA Privacy Law For Private Jets Won’t Stop Taylor And Elon From Popping Up On IRS’s Radar

IRS Adds Several Tax Traps Aimed at Wealthy Individuals to 2024 Dirty Dozen Campaign

Staying On The Right Side Of The Law In Tax Collection Matters

Kostelanetz News Brief: FinCEN Director Stresses Growing Financial Transparency Requirements

Forbes Quotes Megan L. Brackney On New IRS Enforcement Campaign Targeting Individual Taxpayers

The Wall Street Journal Quotes Bryan C. Skarlatos On An Early Bird’s Guide To Preparing Tax Returns

Law360 Quotes Daniel C. Davidson On First Purely Tax Crypto Indictment

Navigating The Unsettled Listed Transaction Landscape

‘Go-To Lawyer for Government Contractors’ Claude Millman Named to ‘Fifty Over 50’ List by City & State

Making Your Case In Tax Court

Covid Crooks Were No Match for IRS In Pandemic Fraud Task Force

Overview of the Corporate Transparency Act: How Companies and their Advisors Can Prepare

IRS Announces Withdrawal Process for Employee Retention Credit Claims

Navigating ERC Tax Audits and Investigations: Part One

The Supreme Court Will Determine Constitutionality Of The Mandatory Repatriation Tax

ChatGPT for Legal and Tax Professionals

Trump Cases Put the Crime-Fraud Exception in the Spotlight

WATCH: Kostelanetz Goes to Cambridge International Symposium on Economic Crime

Payroll Tax Evasion Notice Suggests FinCEN’s New Focus

Diversity In The Tax Bar — Reflections On Lessons Learned And The Path Forward

Garrett L. Brodeur Quoted In Law360 Article Titled “IRS Floats First-Ever Broker Rules For Digital Asset Sales”

IRS Doesn’t Have It Easy With Malta Pension Enforcement Efforts

Garrett L. Brodeur Quoted In Daily Tax Report Titled “Crypto Tax Guidance Confusion Heralds Court Battles to Come”

Caroline D. Ciraolo Quoted In Tax Notes In An Article Entitled “IRS Penalty Practice May Be Due for Reset”

Diamonds in the Rough Notes: The Importance of Obtaining Informal Notes of Witness Statements

When Past Is Prologue: Why the Justice Department’s Revised Corporate Enforcement Policies May Create More Problems Than They Solve

Kostelanetz Alert: IRS Issues Proposed Regulations Identifying “Monetized Installment Sales” as Listed Transactions

IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

Christopher M. Ferguson Quoted In Tax Notes Article Entitled “IRS May Face Constraints in Quest to Curb ERC Abuse”

Garrett L. Brodeur Quoted In Tax Notes Article Titled “Senate Call for Crypto Tax Input Shows Progress for Industry”

Garrett L. Brodeur Quoted In Bloomberg Law Article Titled “Crypto Appeal Tests Ability to Challenge IRS Positions in Court”

An Inconvenient Truth About Remote Work

Revisions to Form 14457 Could Facilitate Crypto Disclosures

Michael Sardar Quoted In Yahoo Finance In An Article Entitled “IRS gets major power to request private tax info after Supreme Court decision”

The State of the Tax Whistleblower Law

Garrett L. Brodeur Quoted In Tax Notes In An Article Entitled “Crypto Reg Delay Ruffles Lawmakers”

Kostelanetz News Brief: SCOTUS Rules IRS Need Not Notify Third Parties Of Summonses For Records Of Their Bank Accounts In Which The Taxpayer Has No Legal Interest

What CPAs Need To Know About Employee Retention Credit Fraud

ABA Tax Section Names Garrett Brodeur Vice Chair of Tax Practice & Technology Committee

ChatGPT – A Piece Of The Puzzle, Not A Panacea

Puerto Rico’s Act 60 Tax Incentive Program Attracting Heightened IRS Scrutiny Of Sourcing And Transfer Pricing

Natural Disasters And Tax Consequences: Individuals And Businesses Take Note

IRS Completes Its 2023 Dirty Dozen List of Tax Scheme Warnings

Kostelanetz News Brief: Legislation To Implement U.S. Obligations Under OECD International Corporate Minimum Tax Agreement Faces GOP Opposition

Enforcing The Nation’s Tax Laws Fully, Fairly, And Consistently: The Role Of DOJ In Tax Enforcement

Reassessing The Erroneous Refund Penalty: The IRS Flexes An Obscure Authority

Tax Refunds For Individuals: A Closer Look

WATCH: Grand Jury Investigations A Focus During “What’s Coming Down the Hill”

WATCH: Senate Finance General Counsel Tiffany Smith Delivers Keynote At “What’s Coming Down the Hill”

IRS Names Employee Retention Credit Promotions To Its 2023 Dirty Dozen, Enforcement Actions Likely

Tax Penalties To Avoid: Taxes Are High Enough Already

Liz Grant Featured In Mock Trial Masterclass Podcast Titled “How to Practice and Prepare for Mock Trial Tournaments””

Kostelanetz Welcomes Two New Spelman Interns for Spring 2023

Key Changes From SECURE Act 2.0

Crypto In Bankruptcy: Tax Apocalypse For Celsius Customers?

Tax Identity Theft: What’s Happening And What You Can Do About It

Tax Changes In The Inflation Reduction Act of 2022

Seven Ways To Decrease Stress At Work

Coffee, NFTs, And Noncompliance?

Don Fort Quoted In Wall Street Journal Article Entitled “First Came the Crypto Crash. Now Comes the Taxman.”

The Lawyer’s Guide To Cryptocurrency: Ethical, Tax, And Reporting Issues With The Receipt Of Cryptocurrency As Payment For Legal Services

K&F News Brief: The IRS Reminds Businesses Of The Work Opportunity Tax Credit

K&F Recognized As Top Tier Firm In International Tax Review/World Tax’s 2023 Rankings

New Crypto Tax Question Foreshadows IRS Enforcement Priorities

K&F’s Spelman Internship Program: A Conversation With Our Remarkable Alumni

K&F Files Amicus Brief With SCOTUS On Behalf of ACTC, Arguing For Fairness In Non-Willful FBAR Penalties

K&F News Brief: DOJ Uses John Doe Summons On Crypto Dealer To Remind Taxpayers To Report Crypto Transactions

K&F News Brief: The IRS Reminds Taxpayers to Beware of Scammers

Tips On Qualified Small Business Stock Exclusions

Old Dog, New Tricks? The New York FCA and Crypto-Tax Compliance

Chambers Recognizes K&F As A Top-Tier Firm For High Net Worth Clients

Tax Implications of Dobbs for Interstate Travel Expenses to Obtain Abortions

U.S. Supreme Court Agrees to Review Major FBAR Penalties Case

How The Wealthy Commit International Tax Evasion: A Case Study

K&F And Six Attorneys Recognized By Chambers USA For Skill In Tax Controversy, Tax Fraud, And White-Collar Defense

‘Flat Sum’ Settlements: An ‘End Run’ Around New York’s Reporting Requirements?

The First-Time Abatement Policy—Harsh Realities And Strategic Considerations

The Trust Fund Recovery Penalty: Who Is Responsible To Pay?

Tax Controversies: Audits, Investigation, Trials (41st edition)

Op-Ed: City Comptroller Should Use All Tools In His Arsenal To Help Human-Services Sector

Jay R. Nanavati Quoted In Law360 Article Entitled “Attys Say Journalism Pushed Gov’t Toward Tax Transparency”

K&F News Brief: IRS Nationwide Tax Forum Set For July 29

K&F Files Amicus Brief Asking SCOTUS To Review Key FBAR Penalties Case

K&F News Brief: IRS Reminds Taxpayers Of Reporting Requirements For Virtual Currency Transactions

The IRS’ Authority To Seize Assets In Foreign Jurisdictions To Satisfy FBAR Penalties

K&F News Brief: IRS Is Committed To Ensuring Taxpayers Pay No More Than The Correct Amount Of Tax

Recent Developments In FBAR Jurisprudence

K&F News Brief: Acting Director of FinCEN Discusses Modern Threats and New Innovations in AML/CFT

K&F News Brief: IRS Publishes Guidance On FAQs And Addresses Reliance Concerns

K&F News Brief: IRS Advisory Council Publishes 2021 Annual Report

K&F News Brief: New York City’s Ethics Law May Lead To Early Exits At City Agencies

The IRS’s Big Plans For Big Data

Caroline D. Ciraolo Quoted In Tax Notes News Article Entitled “Maryland Tax Court Won’t Issue Opinion on Foreign Earned Income Matter”

K&F News Brief: Treasury Announces Ransomware Compliance Guidance

Megan L. Brackney Quoted In CBS News Article Entitled “What’s Inside The Treasury’s Proposal To Track Nearly All Bank Accounts”

John Doe Summonses, Cryptocurrency, and the Taxpayer First Act

Calling For Backup: When Do You (Or Your Clients) Need To Bring In Counsel?

K&F News Brief: IRS Reminds About Critical Worker Classification During National Small Business Week

Increasing Diversity In Tax Law

Nine K&F Attorneys Named To Best Lawyers In America For 2022, And Caroline Ciraolo Selected “Lawyer of the Year” For Tax Litigation And Controversy In D.C.

A Primer On Establishing A Trust And Its Taxation

K&F News Brief: IRS Summer Campaign — Fighting Identity Theft With Security Education

Biden Promised To Bring In $700 Billion By Beefing Up The IRS And Going After Tax Cheats. 2 Former IRS Commissioners Explain How He Can Actually Do It.

OPR’s Star Chamber: Felons And The IRS’s Opaque Sanctions Process

What To Do When You’re Under The Government’s Microscope

Penalties – The IRS’s New Practice Of Assessing Late-Filing Penalties On Timely Filed Substitute Forms 3520-A

The IRS Ramps Up Cryptocurrency Enforcement

Tax Controversies: Audits, Investigations, Trials (40th Edition)

Best Lawyers’ “Women In The Law” List Recognizes Three K&F Partners

K&F News Brief: FinCEN To Host Unusual Workshop On Privacy Enhancing Technologies

Navigating the IRS’s Self-Dealing Rules for Private Foundations

Employers Beware! Payroll Tax Violations Come With A Very Heavy Price

K&F And Six Attorneys Recognized As Leaders In Tax Controversy, Tax Fraud And White-Collar Defense By Chambers USA

The IRS Is Underfunded, But It Needs More Than Cash To Stop Tax Cheats

ABA Tax Section Important Civil Developments May 2021 Report

New IRS Safe Harbor Allows 2021 Deduction of Eligible 2020 PPP Expenses

Financial Crimes — Dirty Money Stories Podcast: There’s A Perfectly Reasonable Explanation For That

K&F Joins Pro Bono Initiative To Combat Anti-Asian Violence

Tax Rep Network Podcast Interviews Don Fort And Larry Sannicandro On The IRS’s And DOJ’s Cryptocurrency John Doe Summonses

The IRS’s Assessment Of Penalties On Substitute Forms 3520-A

Playing Catch With A Hand-Grenade: How To Deal With An Unreported Foreign Bank Account In A Divorce

Promoting Diversity, Inclusion, And Equality Through Pro Bono Service

Robert M. Russell Quoted In Law360 Article Entitled “Speed Of TCJA Passage May Handicap Treasury In Disputes”

An E-Sign Of Changing Times: IRS Now Permits Online Filing Of Forms 2848 And 8821

Caroline D. Ciraolo Quoted In Tax Notes Article Entitled “Practitioners Fear Pandemic’s Impact on Voluntary Disclosures”

How To Delegate Payroll, Employee-Related Tax Filings, And Associated Employer Duties To A Professional Employer Organization

Showing Us How To Get It Done: Nina Olson

White Collar Criminal Investigations Slowing Down? Think Again…The Increase in Employment Tax Prosecutions

AMLA 2020: Sweeping New AML Laws Have Broad Impacts on All Financial Crimes

PENALTIES—Reconsidering the Reasonable Cause Defense to Late-Filing Penalties and the Impact of the Service’s Clarification of the DIIRSP

K&F In The Classroom: International Tax Controversy At Georgetown Law Spring 2021

Robert M. Russell Quoted In Tax Notes Article Entitled “LB&I Campaigns Aim To Advise Taxpayers, Not Increase Audits”

FinCEN Action on Capital One Sends Clear Message on BSA Compliance

The New Age of International Criminal Tax Enforcement

When Client Relationships Don’t End Amicably

Tax Treatment Of Liquidations Of Partnership Interests

Mitigating IRS Cryptocurrency Enforcement Risk in 2021

Don Fort Receives The Association Of Certified Anti-Money Laundering Specialists (ACAMS) Public-Private Partnership Award

The Impact of the IRS’s Clarification of the DIIRSP

Super Lawyers Selects Caroline Ciraolo as “Top Rated Tax Attorney” in Maryland

Two Georgetown Law School Students Complete Their K&F Externships

The Biden Administration Plans Significant Changes in United States Individual and Corporate Income Taxes and Estate Taxes

More Bankruptcies, More Opportunities and Challenges for CPAs

K&F Selected as Top Tier Commercial Litigation Firm by Best Lawyers

Beyond Tax: Contested Election, Trade War, and the Post-COVID World

Indigent Access To Justice Debated In Luxury Condo Appeal

A Tax Case Key To Justice Ginsburg’s Equal Protection Fight

An Update On Civil FBAR Penalties: Decisions Since June 2019 Citing Williams And Mcbride In Discussing The Willful Civil FBAR Penalty

Focus On High Net Worth Nonfilers

Proposed Regulations Provide Guidance On Deducting Fines And Penalties Paid To The Government: Important Questions Still Remain

Reporting Foreign Accounts On The FBAR Versus Form 8938

Bryan Skarlatos Quoted In “IRS Sends Warning Letter To 10,000 Crypto Speculators,” Mish Talk

Christopher M. Ferguson Quoted In Mercury News Article Entitled “A Lafayette Youth Baseball League Supposedly Got A $5 Million PPP Loan. Here’s What Really Happened”

When Money Costs Too Much: Section 8300 Filing Requirements And Penalties