Caroline Ciraolo Selected As “Leading Lawyer” Kostelanetz LLP has been recognized for 2023 as a leading tax controversy firm by The Legal 500, and Caroline Ciraolo has been recognized as a “Leading Lawyer” by the independent legal rankings agency. In selecting Kostelanetz for recognition in its “US Taxes: Contentious” category, The Legal 500
The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60 participants engaging in a ”[h]igh-dollar
In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et al. v. United States, Case
As reported in our last news alert, the IRS is moving aggressively to investigate Malta Pension Plans. This is after naming Malta Pension Plans to the IRS’s Dirty Dozen (its annual list of abusive transactions), issuing a Competent Authority Arrangement walking back the tax benefits otherwise allowed under the U.S.-Malta
Malta Pension Plan arrangements under the United States-Malta Income Tax Treaty are a top enforcement priority of the IRS, finding their way onto the annual Dirty Dozen list. Yesterday, the IRS intensified its efforts as Special Agents from IRS Criminal Investigation (IRS-CI) descended on numerous participants in the Malta Pension
Michael Sardar was quoted in a recent article in Yahoo Finance entitled “IRS gets major power to request private tax info after Supreme Court decision,” published on June 11, 2023. The article discusses the ramifications of Polselli v. International Revenue Service on taxpayer and third-party privacy. The article notes: Last month,
On July 11, 2023, Don Fort provides opening remarks and will lead a panel of experts to open the summit titled “Robots and Robbers: Financial Crime Technology Summit,” a three-day virtual financial crime summit presented by The Financial Crime Academy. Description: Technology has made great advancements in the financial world,
On June 28, 2023, Caroline D. Ciraolo participates in a panel titled “Coming in from the Cold: The Future of Voluntary Disclosures” for the CPA Academy. Description: For more than 70 years, the IRS has had a voluntary disclosure policy designed to encourage taxpayers to come in from the cold
