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Tag: Appellate Litigation

IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

By Michael Sardar, Don Fort, and Caroline Ciraolo Law360 July 28, 2023 Malta pension plan arrangements under the U.S.-Malta income tax treaty have been a focus of the Internal Revenue Service and U.S. Department of the Treasury for more than two years. That focus intensified recently as special agents from

Megan L. Brackney Quoted In Tax Notes Article Entitled “IRS Appeals Training Materials on Reasonable Cause Worry Practitioners”

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

Indigent Access To Justice Debated In Luxury Condo Appeal

By Claude M. Millman, with Russell A.S. Wirth New York Law Journal October 1, 2020 The New York State Court of Appeals is poised to hear oral argument in a case about the financing of a luxury, residential tower on Sutton Place in Manhattan—but some not-for-profits are saying that the outcome could