By Michael Waalkes The CPA Journal January 2024 Due to recent taxpayer-favorable court decisions requiring the Department of the Treasury to use formal notice-and-comment procedures under the Administrative Procedure Act (APA), the process by which the IRS publicly identifies listed transactions has undergone significant changes. It remains unclear whether these
Andy Weiner was quoted in an article published by The Washington Post on November 27, 2023, titled “This lawsuit could disrupt the U.S. tax system. Key facts are in dispute.” The article discusses Charles G. Moore et al. v. United States (No. 22-800) in the Supreme Court that challenges the transition
Andy Weiner was quoted in a Law360 article titled “Tax Profs Urge Justices to Uphold Repatriation Levy” on October 20, 2023. The Supreme Court will hear a challenge to the transition tax under Internal Revenue Code Section 965 in the case Charles G. Moore et al. v. United States (No.
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
