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
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
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
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
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
