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
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
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
The Financial Crimes Enforcement Network (FinCEN) announced on Oct. 11, 2024, that it would extend the filing deadline for Reports of Foreign Bank and Financial Account (FBARs Form FinCEN 114) for people impacted by Hurricane Milton as well as those who have been impacted by the war between Israel and Hamas
Bryan C. Skarlatos was quoted in a recent Wall Street Journal article titled “A Tax-Shelter Crackdown Uncovers a Dentist’s ‘Smile High Trust,’” which examines IRS enforcement efforts against tax shelter promotions involving alleged tax-reducing trusts that are targeted to “wealthy individuals, business owners and professionals like doctors and lawyers.” The
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
The Financial Crimes Enforcement Network (FinCEN) today announced that it would extend the filing deadline for Reports of Foreign Bank and Financial Account (FBARs Form FinCEN 114) for people impacted by recent natural disasters in the United States, including Hurricane Helene, Hurricane Debby, Hurricane Beryl, and Tropical Storm Francine. For
Kostelanetz LLP Partner Megan L. Brackney is calling for an end to IRS foreign gift penalties, arguing that the current law is inefficient and punitive to lower- and middle-income taxpayers with foreign relatives. In an op-ed for Bloomberg Tax, Ms. Brackney addresses concerns raised by the Taxpayer Advocate Service and
In an August 24, 2024 decision, Varian Medical Systems Inc. v. Commissioner (Varian), the Tax Court offered a first view of how it will analyze challenges to Treasury regulations after the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo (Loper Bright). Loper Bright reversed the four-decades-old Chevron doctrine of
NEW YORK (September 4, 2024) — Kostelanetz LLP has been recognized by International Tax Review/World Tax as a top-tier firm for tax controversy in the publication’s 2025 rankings guide. Additionally, four of the firm’s partners have been recognized as “Highly Regarded” tax controversy practitioners. Both the New York and Washington, D.C. offices are
