In a unanimous opinion delivered by Chief Justice John Roberts on May 18, 2023, the Supreme Court ruled that the Internal Revenue Service was not required to notify an individual and two law firms of summonses seeking their banking records. In the matter of Polselli et al. v. Internal Revenue
On June 8, 2023, Andrew Weiner moderates a panel titled “The Administrative Procedure Act v. The IRS: Which Regulations, Rules, And Notices Will Survive?” at the NYU Tax Controversy Forum. Description: Ever since the Supreme Court rejected tax exceptionalism in Mayo Foundation v. United States, 562 U.S. 44 (2011), challenges
On July 11, 2023, Megan L. Brackney presents a webinar on “Ethical Issues in Practice Before the IRS” for the CPA Academy. Description: This session covers the provisions of Circular 230 and the AICPA Statements on Standards for Tax Services that apply when interacting with the IRS during audits, appeals,
Don Fort participates in the Cambridge Forum on International Tax & Disputes in Cascais, Portugal. Description: The Forum Steering Committee welcomes up to 40 leading lawyers personally selected from renowned regional, national, and multinational firms around the world. With increased transparency and information sharing amongst tax authorities, the use of
Caroline D. Ciraolo co-chairs the Cambridge Forum on International Tax & Disputes in Cascais, Portugal. Description: The Forum Steering Committee welcomes up to 40 leading lawyers personally selected from renowned regional, national, and multinational firms around the world. With increased transparency and information sharing amongst tax authorities, the use of
Caroline D. Ciraolo leads a discussion titled “You’ve Got a Friend – Leveraging Relationships with Treaty Partners…” at the Forum on International Tax & Disputes presented by Cambridge Forums. Description: Faced with substantial tax gaps, aggressive tax avoidance, and abusive tax structures, tax authorities around the world are increasing civil
On May 3, 2023, Megan L. Brackney participates in a panel titled “Hot Button Topics with the IRS: A Conversation with Three Tax Controversy Practitioners” for STEP NY. Description: In this panel, Lawrence Lipoff leads a conversation with Megan L. Brackney, Thomas Ostrander and Miri Forster, three tax controversy experts, about
On June 1, 2023, Andrew Weiner presents on a panel titled “Key Developments in Tax Controversy” at the FBA Insurance Tax Conference. Description: This panel will cover several recent, critical developments in the tax controversy space. The program will provide the attendees with an understanding of the Inflation Reduction Act
