Lawrence (Larry) A. Sannicandro was quoted in a recent Tax Notes article entitled “There May Be a Few Ways to Improve Tax Court Limited Appearances,” published on February 3, 2021. Sannicandro advocates for issue-based representation in proceedings before the United States Court to allow the court to more easily hear
Michael Sardar was quoted in a recent Bloomberg Tax article entitled “Tax Attorneys Hope for Congress to Expand Reach of Tax Court,” published on January 29, 2021. Sardar discusses how Congress could pass legislation that would allow for the U.S. Tax Court to take on refund cases. The article notes:
Megan L. Brackney was quoted in a recent Tax Notes article entitled “Future Easement Charges Could Pivot on Economic Substance Questions,” published on January 29, 2021. Brackney discusses the potential future nature of syndicated easement charges and the legal issues facing easement promoters. The article notes: Megan L. Brackney of
Robert M. Russell was quoted in a recent Tax Notes article entitled “LB&I Campaigns Aim to Advise Taxpayers, Not Increase Audits,” published on January 29, 2021. Russell observes that some LB&I compliance campaign treatment streams have raised questions from taxpayers. The article notes: Robert Russell of Kostelanetz & Fink LLP
Caroline D. Ciraolo and Paul Butler were quoted in a recent Law360 article entitled “Pa. Judge’s Ruling in FBAR Case Could Add to Gov’t Arsenal,” published on January 25, 2021. Ciraolo and Butler discuss the implications of a recent court ruling on the imposition of willful FBAR penalties. The article
By Dan Davidson The CPA Journal December 2020/January 2021 Edition It is never pleasant when a client relationship ends on less than amicable terms. This is especially true when the relationship’s demise leads to litigation. A contract dispute that was recently litigated in bankruptcy court [In re Kent, 615 B.R. 171
On December 11, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Notice 2020-1 (the Notice) which extends until April 15, 2022 the deadline to file Reports of Foreign Bank and Financial Accounts (FBARs) (FinCEN Form 114) for certain officers, employees, or agents of a U.S. entity who have signature or
Recent clarifications to the Delinquent International Information Return Submission Procedures (“DIIRSP”) remind taxpayers and their advisors of the need to understand the standards, case law, and administrative guidance that apply to requests to have late-filing penalties abated on the ground of reasonable cause. In June 2014, the Internal Revenue Service’s
