Lawrence Sannicandro Archives - Page 2 of 2

PENALTIES—Reconsidering the Reasonable Cause Defense to Late-Filing Penalties and the Impact of the Service’s Clarification of the DIIRSP

By Lawrence Sannicandro Journal of Tax Practice & Procedure Winter 2020 Edition During the 2019 fiscal year, the Internal Revenue Service (“Service” or “IRS”) assessed more than 4.7 million late-filing penalties that cost taxpayers nearly $9.9 billion. These late-filing penalties account for an incredible 24% of the total $40.5 billion

Lawrence A. Sannicandro Quoted In Tax Notes Article Entitled “There May Be a Few Ways to Improve Tax Court Limited Appearances”

Lawrence (Larry) A. Sannicandro was quoted in a recent Tax Notes article entitled “There May Be a Few Ways to Improve Tax Court Limited Appearances,” published on February 3, 2021. Sannicandro advocates for issue-based representation in proceedings before the United States Court to allow the court to more easily hear

FinCEN Action on Capital One Sends Clear Message on BSA Compliance

FinCEN Flexes Its Muscle with $390 Million BSA Penalty Against Capital One National Association Action Comes on Heels of Passage of the Most Robust AML Reforms in 20 Years On January 15, 2021, the Financial Crimes Enforcement Network (FinCEN) announced that it had reached a settlement with Capital One National

Mitigating IRS Cryptocurrency Enforcement Risk in 2021

The high-stakes game of chicken regarding the IRS's enforcement of tax violations involving cryptocurrency holders is poised to move to the next level in 2021, K&F Director of Investigations Don Fort and Partner Lawrence Sannicandro explain in a recent Law360 article. After several years of warning taxpayers about civil and

Lawrence A. Sannicandro Chairs The Tax Collection, Bankruptcy, And Workouts Committee’s Programming At The ABA Virtual 2021 Midyear Tax Meeting

On January 28, 2021, Lawrence (Larry) A. Sannicandro chairs the Tax Collection, Bankruptcy, and Workouts Committee’s programming at the ABA Virtual 2021 Midyear Tax Meeting. The ABA Virtual 2021 Midyear Tax Meeting consists of more than 40 CLE programs and two plenary sessions over four days. Participants learn from and

The Impact of the IRS’s Clarification of the DIIRSP

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

Lawrence Sannicandro Joins K&F as Partner

New York (November 5, 2020) — Kostelanetz & Fink, LLP, is pleased to announce that Lawrence (Larry) Sannicandro has joined the firm as a partner. Mr. Sannicandro has spent more than a decade advising clients on tax law and joins K&F from McCarter & English, LLP. At K&F, Mr. Sannicandro