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Tag: Civil Tax Controversies & Trials

The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil

Kostelanetz LLP partner Michael Sardar will lead a session at the 2024 Taxpayer Representation Super Conference, hosted by the American Society of Tax Problem Solvers (ASTPS), from November 12-14, 2024, at Embassy Suites San Antonio Riverwalk. Michael’s session, “The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil,” on November

Voluntary Disclosure: Where Are We Now?

Kostelanetz LLP partner Michael Sardar will participate in a key panel at the 2024 Criminal Tax Fraud and Tax Controversy Conference, hosted by the Tax Section of the American Bar Association (ABA), from December 12-14, 2024, at Wynn Las Vegas. Michael’s panel, “Voluntary Disclosure: Where Are We Now?” will address

Varian Ruling Opens Door for More Companies to Seek Deductions

Kostelanetz LLP Partner Caroline Rule was recently quoted in Bloomberg Tax after speaking with senior reporter Michael Rapoport regarding the Varian ruling, a hot-button issue in international tax compliance for corporations. Varian Medical Systems Inc. v. Commissioner, 163 T.C. No. 4, was decided on August 26, 2024. Varian’s victory in

Ethics in Tax: Standards for Tax Advice

Kostelanetz LLP partner Megan L. Brackney will kick off the Committee of Banking Institutions on Taxation (CBIT) 2024 Fall Tax Day with a session on November 21, 2024, from 9:00-9:55 AM on ethical standards for dispensing tax advice. Known for her extensive knowledge of tax ethics, Megan regularly educates other

‘IRS Enforcement Efforts and the Path Ahead From the Experts’

Kostelanetz LLP partner Megan L. Brackney spoke on two panels at the 83rd NYU School of Professional Studies Institute on Federal Taxation, a six-day program dedicated to high-level discussions on federal tax matters, tax code updates, and key developments in tax administration. Megan’s panels focused on IRS enforcement and professional

U.S. Treasury Issues Final Regulations Identifying Syndicated Conservation Easements as Abusive Tax Transactions

Yesterday, the U.S. Treasury Department issued final regulations (TD 10007, RIN 1545-BQ39) that identify certain syndicated conservation easement transactions (SCE) and substantially similar transactions as “listed transactions.” These SCE transactions must be reported on Form 8886, Reportable Transaction Disclosure Statement. In addition, material advisers to any reportable transaction are required