Caroline Rule Archives - Page 3 of 5

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

By Caroline Rule and Jas Singh The Journal of Tax Practice & Procedure Summer 2021 Issue The IRS has begun systematically imposing late-filing penalties on substitute Forms 3520-A even when they have been filed on time. This new mistaken practice forces a taxpayer who does not owe a late-filing penalty

The IRS Ramps Up Cryptocurrency Enforcement

By Caroline Rule and Daniel Q. Flesch The Journal of Tax Practice & Procedure Summer 2021 Issue At a Federal Bar Association conference in March of this year, Damon Rowe—Director of the Office of Fraud Enforcement at the IRS—announced a new initiative. Operation Hidden Treasure consists of a special joint-effort

Caroline Rule Participates In A Panel Entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” For The National Association Of Women Lawyers

On June 17, 2021, Caroline Rule participates in a panel entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” for the National Association of Women Lawyers. This program will address the scope and applicability of the common interest doctrine to communications among parties aligned in corporate transactions

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

By Bryan C. Skarlatos and Caroline Rule Journal of the American Academy of Matrimonial Lawyers Volume 33 Issue 2 (2021) When it comes to unreported foreign bank accounts, there is good news and bad news. The good news is that a previously unreported foreign bank account can dramatically increase the

Ninth Circuit Rules In Favor Of Taxpayer In Pivotal FBAR Penalties Case

The Ninth Circuit Court of Appeals recently ruled in favor of a taxpayer subject to a non-willful civil penalty for failure to timely file an accurate Foreign Bank Account Report (FBAR), agreeing with a position advanced in a friend of the court brief written by Kostelanetz & Fink partners Caroline

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

By Caroline Rule and Russell A.S. Wirth The CPA Journal February/March 2021 Issue Many small- to medium-size businesses struggle with the burdensome costs of administering payroll, employee-related federal and state tax requirements, and other employee benefits. A related group of companies that finds itself in this situation may choose to establish

FinCEN Issues Notice 2020-1 Extending The FBAR Filing Deadline for Certain Individual Filers With Signature or Other Authority Over A U.S. Entity’s Foreign Bank Accounts

On December 11, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Notice 2020-1 (the Notice) which extends until April 15, 2022 the deadline to file Reports of Foreign Bank and Financial Accounts (FBARs) (FinCEN Form 114) for certain officers, employees, or agents of a U.S. entity who have signature or

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

By: Caroline Rule Journal of Tax Practice & Procedure Fall 2020 Edition This article will discuss cases after June 2019 that have followed, rejected, or partially relied on the precedents of Williams and McBride, which cases include language to the effect that, if a taxpayer signs a Form 1040 income tax

Super Lawyers Recognizes 10 K&F Attorneys For Tax, White Collar Defense, And Business Litigation In New York

NEW YORK CITY, NY (September 29, 2020) – Kostelanetz & Fink is pleased to announce that 10 attorneys at the firm have been selected for inclusion in the 2020 New York Metro Super Lawyers list, recognizing the firm’s experience and skill in the areas of Tax, Criminal Defense: White Collar,

The Government’s New Stance That The Non-Willful Civil FBAR Penalty Applies To Every Account On An Untimely-Filed FBAR, Rather Than To The Single Untimely FBAR Form

By: Caroline Rule Journal of Tax Practice & Procedure Summer 2020 Edition Recent litigation has focused on the government’s new position that the $10,000 non-willful civil FBAR penalty applies per account listed on an non-willfully untimely-filed annual FBAR—a Report of Foreign Bank or Financial Accounts that must be filed by a U.S. person “who

Tag: Caroline Rule

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

The IRS Ramps Up Cryptocurrency Enforcement

Caroline Rule Participates In A Panel Entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” For The National Association Of Women Lawyers

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

Ninth Circuit Rules In Favor Of Taxpayer In Pivotal FBAR Penalties Case

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

FinCEN Issues Notice 2020-1 Extending The FBAR Filing Deadline for Certain Individual Filers With Signature or Other Authority Over A U.S. Entity’s Foreign Bank Accounts

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

Super Lawyers Recognizes 10 K&F Attorneys For Tax, White Collar Defense, And Business Litigation In New York

The Government’s New Stance That The Non-Willful Civil FBAR Penalty Applies To Every Account On An Untimely-Filed FBAR, Rather Than To The Single Untimely FBAR Form

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