Caroline Rule Archives - Page 4 of 5

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

Caroline Rule Article On U.S. v Greenfield Selected For Inclusion In The March/April Magazine Of The ABA General Practice Division

Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2), has been selected for inclusion

Caroline Rule Article On U.S. v Greenfield Selected For Inclusion In The March/April Magazine Of The ABA General Practice Division

A Long Overdue Check On Prosecutorial Power In Tax Cases

By Caroline Rule and Bob Fink Law 360 Twenty years ago, we put forward what was then a novel concept — that the IRS and the U.S. Department of Justice were misusing the tax code to make their jobs easier. Our topic was the misuse of a statute that, we contended, was reserved for prosecuting the deliberate

Federal Criminal Tax Charges And DOJ Tax Division Conference Requests

By Caroline Rule ABA Section of Litigation, Criminal Litigation Committee December 5, 2019 Always request a DOJ Tax Division conference as soon as it appears that your client may face federal criminal tax charges. Suppose that you have a client who can afford for you to travel to Washington, D.C., and

GETTING TAXPAYERS’ CONSENT TO DISCLOSE OR USE TAX RETURN INFORMATION UNDER IRC SECTION 7216

By Caroline Rule The CPA Journal November 2019 Edition Under Internal Revenue Code (IRC) section 7216 and its concomitant regulations, a tax preparer must obtain the consent of a taxpayer before disclosing or using the taxpayer’s tax return information when that consent is required. Section 7216 makes it a crime for

THE CONFIDENTIALITY OF A CLIENT’S TAX RETURN INFORMATION: PROVISIONS TAX PREPARERS MUST REMEMBER

By Caroline Rule The CPA Journal October 2019 Edition Internal Revenue Code (IRC) section 7216 and its lengthy regulations govern when a tax return preparer may disclose or use a taxpayer’s tax return information without first obtaining the taxpayer’s consent. Because it is a federal crime to violate section 7216 and

KOSTELANETZ & FINK ATTORNEYS RECOGNIZED BY NEW YORK METRO AREA SUPER LAWYERS

NEW YORK CITY, NY (September 12, 2019) – Kostelanetz & Fink is pleased to announce that nine attorneys at the firm, including seven partners, have been selected for inclusion in the 2019 New York Metro “Super Lawyers” list, recognizing the firm’s experience and skill in the areas of Tax, Criminal

MARITAL PRIVILEGES

By Caroline Rule The Journal of the Section of Litigation Vol. 45 No. 4 Summer 2019 Marriage is perplexing, and the marital privileges even more so. Contradictory views determine when they apply and what they protect. In many states, statutes, rather than case law, govern, but federal law leaves it to

The People Of The State Of New York Vs. M. Robert Neulander – Brief For Amicus Curiae In Support Of Defendant-respondent

Caroline Rule, as Counsel to the New York Council of Defense Lawyers, authored an Amicus Curiae brief in the New York Court of Appeals in regards to the case People v. Neulander in which the prosecution is appealing the Appellate Division, Fourth Department’s grant of a new trial to Mr. Neulander on the grounds of juror

Tag: Caroline Rule

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

Caroline Rule Article On U.S. v Greenfield Selected For Inclusion In The March/April Magazine Of The ABA General Practice Division

Caroline Rule Article On U.S. v Greenfield Selected For Inclusion In The March/April Magazine Of The ABA General Practice Division

A Long Overdue Check On Prosecutorial Power In Tax Cases

Federal Criminal Tax Charges And DOJ Tax Division Conference Requests

GETTING TAXPAYERS’ CONSENT TO DISCLOSE OR USE TAX RETURN INFORMATION UNDER IRC SECTION 7216

THE CONFIDENTIALITY OF A CLIENT’S TAX RETURN INFORMATION: PROVISIONS TAX PREPARERS MUST REMEMBER

KOSTELANETZ & FINK ATTORNEYS RECOGNIZED BY NEW YORK METRO AREA SUPER LAWYERS

MARITAL PRIVILEGES

The People Of The State Of New York Vs. M. Robert Neulander – Brief For Amicus Curiae In Support Of Defendant-respondent

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