As part of Kostelanetz & Fink’s commitment to pro bono work and giving back to the tax community, K&F partners Megan Brackney, Yoram Keinan, Bryan Skarlatos, and Michael Sardar were proud to participate in the most recent IRS Virtual Settlement Conferences in coordination with the IRS’s Office of Chief Counsel on July 28 and
By Megan L. Brackney The CPA Journal June 2020 Edition The Internal Revenue Code and the Bank Secrecy Act (BSA) require that persons engaged in a trade or business file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, any time the business receives more than $10,000
By Megan L. Brackney Tax Notes Federal April 27, 2020 Given that combating tax fraud is a top agency priority, it is a good time to review the law and procedures related to tax fraud. In this article, Megan Brackney discusses the ways the IRS identifies and addresses fraud, the consequences
By Megan L. Brackney Tax Notes In this article, Brackney discusses the John Doe summons procedures and the decision partially enforcing a John Doe summons in Coinbase. She also identifies some practical considerations for taxpayers whose information may be turned over to the IRS in accordance with the summons. Full Article
In a TaxNotes article entitled, “Practitioners Fault Accelerated Assessable Penalty Collection,” Megan Brackney is quoted on how “the IRS’s collections practice for assessable penalties related to foreign information returns is increasingly placing taxpayers in a bind, and practitioners are eager to provide suggestions on how the process can be improved.”
Megan Brackney was named by Lawline as one of the “Top Women Faculty of 2019” for a CLE program she taught entitled “Tax Procedure: IRS Methods of Obtaining Information From and About Taxpayers.” Lawline noted that the program “has received 500 views and counting since the December 2019 live broadcast.” Lawline,
Drawing on their deep experience representing clients facing some of the most challenging and complex tax controversy matters, Kostelanetz & Fink partners Bryan Skarlatos and Megan Brackney have for years been bringing their expertise into the classroom as adjunct professors at New York University School of Law. This spring, Mr.
By Megan L. Brackney Procedurally Taxing January 8, 2020 The Gifts That Keep on Giving Two young people moved to the U.S. as students. They met in graduate school and married. After graduation, they were offered jobs and were sponsored by their employers so that they could stay in the U.S.
By Megan L. Brackney Procedurally Taxing January 7, 2020 Reasonable Cause For all of the foreign information return penalties, reasonable cause is a defense. See I.R.C. §§ 6038, 6038A(d)(3), 6038D(g), 6039F(c)(2), 6677(d); Treas. Reg. § 1.6038-2(k)(3)(ii). The IRS applies the same standards for reasonable cause for failure to file income tax returns under I.R.C. § 6651 to failure to file foreign
By Megan L. Brackney Procedurally Taxing January 6, 2020 The IRS has been assessing more and more foreign information return penalties on taxpayers. It is difficult to find statistics on this point, as the IRS’s reports on tax penalties lump all “nonreturn” penalties into one category, which includes failure to file Forms
