On August 22, 2023, Heather Fincher participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford. CPE Credit is offered for this event. Description: This course provides tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact
Garrett L. Brodeur was quoted in a recent Bloomberg Law article titled “Crypto Appeal Tests Ability to Challenge IRS Positions in Court” and published on July 25th, 2023. A consequential case in the US Court of Appeals for the 6th Circuit will decide whether the IRS can end a couple’s lawsuit over
Megan Brackney, Caroline Ciraolo, and Bryan Skarlatos Also Named Leading Lawyers NEW YORK (July 25, 2023) — Kostelanetz LLP and three attorneys have been recognized by Chambers and Partners as a top-tier U.S. law firm in its 2023 High Net Worth (HNW) Guide under the category of Tax: Private Client. In addition to
Caroline D. Ciraolo was quoted in a recent Bloomberg Tax article titled “IRS Goes After Wealthy Tax Scofflaws as More Complex Cases Brew,” published July 18th, 2023. The article discusses recent Internal Revenue Service efforts to bolster their enforcement capabilities as enforcement issues increase in complexity. The article notes: The IRS
Caroline Ciraolo Selected As “Leading Lawyer” Kostelanetz LLP has been recognized for 2023 as a leading tax controversy firm by The Legal 500, and Caroline Ciraolo has been recognized as a “Leading Lawyer” by the independent legal rankings agency. In selecting Kostelanetz for recognition in its “US Taxes: Contentious” category, The Legal 500
On August 23, 2023, Michael Sardar participates in a webinar panel titled “Nuts and Bolts of Tax Litigation: Administrative Process Summary, Choice of Forum, Initiating a Case” for the ABA Tax Section. CLE credit is offered for this event. Description: This is the first of a four-part webinar series discussing
The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60 participants engaging in a ”[h]igh-dollar
In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et al. v. United States, Case
By Garrett L. Brodeur Tax Notes Federal July 3, 2023 In a recent Letter to the Editor, Garrett L. Brodeur noted that several recent informal guidance documents on the tax treatment of cryptoassets suggest that the IRS is striving to provide meaningful direction, even under significant budgetary and resource constraints
