Kostelanetz has filed an amicus brief on behalf of Professors Reuven Avi-Yonah, Clinton Wallace, and Bret Wells in the U.S. Supreme Court case of Charles G. Moore v. United States (No. 22-800). The case involves a constitutional challenge to the transition tax under Section 965 but the implications are far-reaching.
By Caroline Ciraolo, Don Fort, and Ian Weinstock Bloomberg Tax August 28, 2023 High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the
Caroline D. Ciraolo was quoted in a Tax Notes article titled “IRS Penalty Practice May Be Due for Reset,” published on August 16, 2023. The article addresses the current state of penalty administration and notes Caroline Ciraolo’s concerns regarding the Internal Revenue Service’s current approach to the consideration and assessment
On August 15th, 2023, Caroline Ciraolo participates in a webinar panel titled “IRS Penalty Policy and Practice” as part of a webinar series titled “Transforming Tax Administration” presented by Center for Taxpayer Rights. Description: Center for Taxpayer Rights presents a series of webinars from March 23, 2023 through August 31,
Garrett L. Brodeur was quoted in a recent Tax Notes article titled “Staking Case Raises a Question: Can IRS Be Rushed Into Guidance?,” published on July 28th, 2023. The article discusses Jarrett v. United States, a tax case concerning cryptocurrency staking rewards. The case is currently on appeal to the
On January 9, 2023, the United States Supreme Court will hear oral argument in In re Grand Jury, a landmark case regarding a Kostelanetz client’s assertion of the attorney-client privilege during a grand-jury investigation. The Kostelanetz client asserted the attorney-client privilege over communications between the client and the client’s prior lawyers in
Megan L. Brackney was quoted in an article in Tax Notes titled “IRS Appeals Training Materials on Reasonable Cause Worry Practitioners” on October 6, 2022. The article discusses the implications of recently disclosed training materials related to international information return penalties from the IRS Independent Office of Appeals. Practitioners are particularly concerned
Brian C. Wille was quoted in a recent Law360 article entitled “DC Circ. Urged To Undo Tax Court Tipster Denial In $60M Case,” published on April 25, 2022. The article discusses amici briefs filed in an appeal pending before the D.C. Circuit in which amici argued in favor of overturning
Kostelanetz & Fink served as counsel of record on behalf of the American College of Tax Counsel, which filed an amicus brief in the case of Alexandru Bittner v. United States on April 1, 2022. The College’s brief argued in support of the petition for a writ of certiorari seeking
