The IRS responded swiftly to the Tax Court’s recent decision, Green Valley Investors, LLC, et al. v. Comm’r, 159 T.C. No. 5 (Nov. 9, 2022), which invalidated IRS Notice 2017-10, identifying syndicated conservation easements as “listed transactions,” on the ground that the Notice violated the prior notice and comment requirements
Megan L. Brackney guest authored a two-part series for the Procedurally Taxing Blog entitled “The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners.” The two posts raise important questions about practitioners’ ethical responsibilities when confronting clients’ potential exposure to penalties for failing to file
Caroline D. Ciraolo shared her insight in a recent Tax Notes article by Lauren Loricchio entitled “Documents Shed Light on IRS Scrutiny of Employee Retention Credit” published on December 5, 2022. The article details the IRS’s issuance of training materials that explain how examiners should scrutinize the use of the
As part of Kostelanetz’s commitment to pro bono work and giving back to the tax community, on December 5, 2022, Kostelanetz sponsored the New York County Lawyers Association’s (NYCLA) Tax Court Calendar Call Pro Bono Program. NYCLA’s U.S. Tax Court Calendar Call Pro Bono Program matches attorneys with unrepresented taxpayers
Kostelanetz LLP brings extensive trial experience to its work for firm clients. Two of our ten partners — Sharon L. McCarthy and Jay R. Nanavati — are Fellows of the American College of Trial Lawyers; Best Lawyers named us “Law Firm of the Year” for Tax Litigation in 2021 and
Caroline D. Ciraolo speaks about tax litigation, recent decisions and their impact on corporate and individual taxpayers at the D.C. Bar’s Annual Tax Legislative and Regulatory Update Conference on January 26, 2023. Moderator: Michael Desmond, Partner, Gibson Dunn & Crutcher LLP Panelists: Caroline D. Ciraolo, Partner, Kostelanetz LLP Andrew Strelka,
The Internal Revenue Service Advisory Council (IRSAC) serves as an advisory body to the Commissioner of the Internal Revenue Service (IRS or Service), making recommendations about tax administration and advising about the public’s expectations of the IRS. This year’s Council has 34 members with significant experience in providing tax advice
Caroline D. Ciraolo participates in a panel titled “Targeting the Tax Professional: A Review of the Increased Civil and Criminal Tax Enforcement Against Attorneys, Accountants, and other Financial Advisors” at the 41st Annual Florida Bar/FICPA International Tax Conference. CPE credit is offered at this event. Panel Description: Tax enforcement is
Caroline D. Ciraolo speaks about tax litigation at the 12th Annual London Finance and Capital Markets Conference on January 17, 2023 in London, England. Description: Panelists from around the world offer their unique perspectives on civil and criminal tax enforcement and trends. Session Chairs: Jonathan Schwarz, Temple Tax Barristers (London,
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