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Tag: International Tax Controversies

Tax Enforcement Trends: What’s Hot and What’s Not

Kostelanetz partner Christopher Ferguson will speak at the IRS Representation Conference on November 8, 2024. He is a panelist for the session “Enforcement Trends: What’s Hot and What’s Not” that will be held from 10:15 AM to 11:05 AM Eastern. The panel will cover a variety of tax enforcement topics,

The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil

Kostelanetz LLP partner Michael Sardar will lead a session at the 2024 Taxpayer Representation Super Conference, hosted by the American Society of Tax Problem Solvers (ASTPS), from November 12-14, 2024, at Embassy Suites San Antonio Riverwalk. Michael’s session, “The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil,” on November

Voluntary Disclosure: Where Are We Now?

Kostelanetz LLP partner Michael Sardar will participate in a key panel at the 2024 Criminal Tax Fraud and Tax Controversy Conference, hosted by the Tax Section of the American Bar Association (ABA), from December 12-14, 2024, at Wynn Las Vegas. Michael’s panel, “Voluntary Disclosure: Where Are We Now?” will address

Varian Ruling Opens Door for More Companies to Seek Deductions

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

‘IRS Enforcement Efforts and the Path Ahead From the Experts’

Kostelanetz LLP partner Megan L. Brackney spoke on two panels at the 83rd NYU School of Professional Studies Institute on Federal Taxation, a six-day program dedicated to high-level discussions on federal tax matters, tax code updates, and key developments in tax administration. Megan’s panels focused on IRS enforcement and professional

‘Draconian’ IRS Foreign Gift Penalties Serve No Practical Purpose

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