This spring, Caroline Ciraolo and Robert Russell will again bring their decades of experience in federal tax enforcement and tax controversy matters to Georgetown University Law Center and Graduate Tax Program in a class entitled, “International Tax Controversy.” Professors Ciraolo and Russell concentrate the course on real world civil and
Caroline D. Ciraolo and Paul Butler were quoted in a recent Law360 article entitled “Pa. Judge’s Ruling in FBAR Case Could Add to Gov’t Arsenal,” published on January 25, 2021. Ciraolo and Butler discuss the implications of a recent court ruling on the imposition of willful FBAR penalties. The article
On December 11, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Notice 2020-1 (the Notice) which extends until April 15, 2022 the deadline to file Reports of Foreign Bank and Financial Accounts (FBARs) (FinCEN Form 114) for certain officers, employees, or agents of a U.S. entity who have signature or
Recent clarifications to the Delinquent International Information Return Submission Procedures (“DIIRSP”) remind taxpayers and their advisors of the need to understand the standards, case law, and administrative guidance that apply to requests to have late-filing penalties abated on the ground of reasonable cause. In June 2014, the Internal Revenue Service’s
This Fall, K&F hosted two students completing Georgetown Law School’s LLM program in tax law. Sarah McIntosh and Sadi Moradi joined us as externs while they studied post-graduate level tax law at Georgetown. Ms. McIntosh expects to earn her LLM this Spring and has previously interned at the Office of
By: Sidney Kess and Thomas K. Lauletta Estate Planning Review—THE JOURNAL VOLUME 46 | ISSUE 10 | OCTOBER 22, 2020 Many experts are focusing primarily on the tax issues that are likely to arise as a result of the election, such as changes in the wealth tax and estate taxes. We
By Usman Mohammad The CPA Journal August 2020 Edition Because U.S. taxpayers are required to report and pay taxes on their worldwide income, the U.S. government has fought to compel taxpayers to report their interests in overseas bank accounts. In the 1970s, the FBAR (Report of Foreign Bank and Financial Accounts) was created as part of
By Usman Mohammad The ABA Tax Times Vol. 39 No. 3 – Spring 2020 Puerto Rico, American Samoa, Guam, The United States Virgin Islands, The Northern Mariana Islands—these are all United States territories or possessions. Individuals born in these territories are deemed by law to be either United States citizens or
