You could easily be forgiven for not knowing the current state of the Corporate Transparency Act (“CTA”) following the Fifth Circuit’s holiday flip-flop…or the Supreme Court subsequently weighing in…or Congress’s umpteenth attempt to push off the law’s effective date…or the recent flurry of FinCEN press releases. But the most important
NEW YORK (Jan. 24, 2025) — Kostelanetz LLP is pleased to announce that Eduardo A. Cukier has joined the firm as a counsel focused on corporate, international, and high-net-worth tax planning and transactions. Eduardo brings more than two decades of experience in transactions-based domestic and international tax practice. He advises
By Ian Weinstock and Heather Fincher After 15 years of waiting, we now have final regulations providing guidance on the tax imposed by Internal Revenue Code Section 2801 (the “Section 2801 tax”) for U.S. citizens and residents who receive gifts or bequests from certain individuals who have expatriated from the
Kostelanetz partner Michael Sardar participates in an international tax compliance webinar through continuing educator provider Strafford on January 7, 2025. The recorded session is available for purchase. The session, titled “Forms 5471 and 5472: Meeting the Substantially Complete Standards,” covers best practices for meeting the substantially complete standard in filling
Caroline Rule was quoted in a recent Bloomberg Tax article about the broad implications of a corporate tax loophole that the U.S. Tax Court upheld in its August 2024 decision in Varian Medical Systems Inc. v. Commissioner, 163 T.C. No. 4. The article, titled “Cisco, Booking Get Big Tax Benefits
Kostelanetz partner Caroline Ciraolo and Director of Investigations Don Fort participated in multiple panels at the 61st annual Hawaii Tax Institute, the largest tax and wealth transfer conference in the U.S. that takes place in Waikiki Beach in Honolulu. The comprehensive five-day conference covers several aspects of wealth transfers, tax
Kostelanetz partner Michael Sardar was quoted in Tax Notes regarding proposed changes by the IRS concerning taxpayers burdened with penalties stemming for late-filed foreign trust and gift reports (Forms 3520 and 3520-A). The Tax Notes article covered an October 31 panel at the Procopio International Tax Institute conference in San
While speaking at the UCLA Tax Controversy Conference in Los Angeles, IRS Commissioner Danny Werfel announced a change in how the IRS will apply penalties to late reporting of foreign gifts and inheritances and the reporting of foreign trusts. Effective immediately, the IRS will no longer automatically assess penalties on
Kostelanetz LLP partner Michael Sardar will be featured at the 2024 Procopio International Tax Institute (PITI) conference, which will take place from October 30 to November 1, 2024, at the Intercontinental Hotel in San Diego, CA. As part of a breakout session, “IRS International Information Reporting Penalties: Current Updates and
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
