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Tag: International Tax Compliance

Caroline D. Ciraolo Participates In A Panel Titled “Tax Controversy” At The IFA USA 3rd Annual Winter Conference

Caroline D. Ciraolo speaks about tax controversy at the IFA USA 3rd Annual Winter Conference on November 30, 2022. Description: This panel addresses current IRS enforcement efforts, dispute resolution procedures, and litigation of international tax issues. Particular attention is paid to recent transfer pricing cases and government-to-government resolution. Moderator: Steve

Megan L. Brackney Quoted In Tax Notes Article Entitled “IRS Appeals Training Materials on Reasonable Cause Worry Practitioners”

Megan L. Brackney was quoted in an article in Tax Notes titled “IRS Appeals Training Materials on Reasonable Cause Worry Practitioners” on October 6, 2022. The article discusses the implications of recently disclosed training materials related to international information return penalties from the IRS Independent Office of Appeals. Practitioners are particularly concerned

Caroline D. Ciraolo Participates In A Panel Titled “Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!” At The 59th Annual Hawaii Tax Institute

Caroline D. Ciraolo joins a panel titled “Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!” at the 59th Annual Hawaii Tax Institute. We live in a global economy and many clients have sources of income and assets outside the United States. For U.S. persons,

Eleven K&F Attorneys Selected As Best Lawyers For 2023

NEW YORK (August 18, 2022) — Eleven attorneys at Kostelanetz & Fink were recognized this year by U.S. News’ “Best Lawyers in America®” for their 2023 edition. The K&F lawyers that have been selected by their peers for inclusion in Best Lawyers in America for 2023 are: Megan Brackney for Tax Law in New York;

Michael Sardar Teaches A Course Entitled “A Primer On International Information Returns: Basic Filing Obligations, Penalties, And Pathways To Compliance For The Non-Compliant Taxpayer” For New York University’s Advanced Subchapter S Tax Conference

On July 22, 2022, Michael Sardar teaches a course entitled, “A Primer On International Information Returns: Basic Filing Obligations, Penalties, And Pathways To Compliance For The Non-Compliant Taxpayer” for New York University’s Advanced Subchapter S Tax Conference. Course Description: The Advance Subchapter S Conference provides sophisticated knowledge of the “hot

U.S. Supreme Court Agrees to Review Major FBAR Penalties Case

On June 21, 2022, the U.S. Supreme Court agreed to hear a major case regarding IRS penalties relating to Reports of Foreign Bank and Financial Accounts (FBARs). Kostelanetz & Fink represents the American College of Tax Counsel (the “College”), which filed an amicus brief in Alexandru Bittner v. United States