Robert M. Russell, a member of the The American Institute of Certified Public Accountants, was appointed as Chair of the International Technical Resource Panel (TRP) for the 2021-2022 committee year. The International TRP acts as the primary representative for the AICPA before Congress, Treasury, and the IRS on legislative and
Megan L. Brackney was quoted in a recent Tax Notes article entitled “What’s Reasonable for Late-Filed Foreign Information Returns?,” published on June 7, 2021. Brackney discusses the IRS’ practice of automatically assessing penalties on taxpayers who file late international information returns. The article notes: “It’s incredibly frustrating,” said Megan L.
Caroline D. Ciraolo was quoted in a recent Law360 article entitled “DOJ Official Sees Potential Uptick In Asset Repatriation Efforts,” published on May 12, 2021. Ciraolo continues a discussion that took place during the “Collection Abroad, Including Collection of Title 26 and Title 31 International Information Return Penalties” panel at
Robert M. Russell was quoted in a recent Tax Notes article entitled “Senate International Plan Not Without Taxpayer ‘Silver Linings,’” published on April 15, 2021. Russell comments on various proposals within the Senate Democrats’ international tax framework, released on April 5, 2021. The article notes: “In those cases where BEAT’s
The Joint Chiefs of Global Tax Enforcement (J5)— tax authorities of Australia, Canada, Holland, the UK, and the US—recently convened investigators, cryptocurrency experts, and data scientists in a virtual event, “The Challenge,” where the J5 honed in on developing leads and jumpstarting investigations into criminals’ use of the FINtech industry.
In a recent New York Times article entitled “An Accidental Disclosure Exposes a $1 Billion Tax Fight With Bristol Myers,” Bryan C. Skarlatos weighed in on the potential outcome of a tax controversy between the Internal Revenue Service and Bristol Myers Squibb, an American drugmaker. The dispute with the IRS
By Dan Davidson and Destiny Reese PLI Chronicle March 2021 Issue Over 70% of federal tax filings in 2019—including almost 90% of individual income tax returns—were filed electronically. Yet, as tax practitioners know, many federal tax forms continue to require “wet” signatures. Even before the COVID-19 pandemic, there were calls for
The Ninth Circuit Court of Appeals recently ruled in favor of a taxpayer subject to a non-willful civil penalty for failure to timely file an accurate Foreign Bank Account Report (FBAR), agreeing with a position advanced in a friend of the court brief written by Kostelanetz & Fink partners Caroline
