Megan L. Brackney will moderate a panel titled “Enforcement Trends: What’s Hot and What’s Not” at the 2023 IRS Representation Conference on December 1st, 2023. The conference will be held both in-person and virtually. The events are hosted at the Mohegan Sun Hotel & Casino, CT and by the Quinnipiac
By Caroline Ciraolo, Don Fort, and Ian Weinstock Bloomberg Tax August 28, 2023 High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the
Bryan C. Skarlatos, partner at Kostelanetz LLP, was quoted in an article published in Tax Notes on August 23rd, 2023 titled “The FATCA Haystack Remains Just That.” The article discusses unknowns regarding data collected by the Internal Revenue Service through the Foreign Account Tax Compliance Act. Though the IRS strategic
Caroline D. Ciraolo was quoted in a Tax Notes article titled “IRS Penalty Practice May Be Due for Reset,” published on August 16, 2023. The article addresses the current state of penalty administration and notes Caroline Ciraolo’s concerns regarding the Internal Revenue Service’s current approach to the consideration and assessment
Caroline Ciraolo Also Selected ‘Lawyer of the Year’ NEW YORK (August 17, 2023) — Thirteen Kostelanetz attorneys, including all ten partners, have been recognized by “Best Lawyers in America®” in the 2024 edition, and Caroline D. Ciraolo has been named “Lawyer of the Year” for Litigation and Controversy – Tax
As part of a broader effort reflected by the Corporate Transparency Act to combat the use of shell companies for illicit purposes, the Financial Crimes Enforcement Network within Treasury, or FinCEN, issued FinCEN Notice FIN-2023-NTC1 (Aug. 15, 2023) designed to promote reporting by U.S. financial institutions regarding payroll tax evasion and workers’
By Daniel Cady Davidson New York State Bar Association Journal August 16, 2023 For the trial attorney, familiarity with prosecution witnesses’ statements is fundamental to effective trial preparation. A recent federal health care fraud case in Texas (U.S. v. Swiencinski) underscores just how critical it is for defense counsel to
More than four years ago, the Internal Revenue Service (“IRS”) expressed serious concern about monetized installment sales that, through the use of an intermediary and an installment note, purport to defer recognition of gain and income tax due on the sale of appreciated assets despite the seller’s effective, immediate receipt
On Tuesday, September 5th, 2023, Caroline D. Ciraolo presents a keynote address titled “The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement” at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge. Date: 8:00am BST (U.K. Time) on Tuesday September 5th, 2023. A full
On August 29, 2023, Jay R. Nanavati participates on a panel titled “‘The Art of the Deal’ – Negotiating Plea Deals in Criminal Tax Cases” at the Summer Tax Summit presented by the St. Louis Chapter of the Federal Bar Association in St. Louis, MO. CLE credit is offered for
