On February 28, 2023, the U.S. Supreme Court issued a groundbreaking decision in the case of Alexandru Bittner v. United States (No. 21-1195), holding that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) applies on a per-report basis, and not on
On May 11, 2023, Megan L. Brackney presents on a panel entitled, “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Partnership Tax Advisor Should Know” for the Practicing Law Institute’s “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2023” program. Description:
On April 27, 2023, Megan L. Brackney presents on a panel entitled, “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Partnership Tax Advisor Should Know” for the Practicing Law Institute’s “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2023” program. Description:
On May 11, 2023, Megan L. Brackney presents on a panel entitled, “New Partnership Audit Rules” for the Practicing Law Institute’s “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2023” program. Description: The BBA audit rules provide a radically different approach for how adjustments
On March 28, 2023, Megan L. Brackney presents in a webinar entitled, “Challenging the IRS’s Assessment of Penalties for Delinquent Foreign Information Returns”. Description: The IRS has been aggressively assessing penalties for late-filed foreign information returns against taxpayers, many of whom have voluntarily attempted to correct past non-compliance. This program
On January 10, 2023, Megan L. Brackney participates in a webinar titled “Tax Teaching and Adjunct Opportunities” for the American Bar Association. Webinar Description: This webinar is designed for tax practitioners who are current or prospective adjunct professors. The panel of experienced adjunct professors discusses best practices for teaching tax
Megan L. Brackney guest authored a two-part series for the Procedurally Taxing Blog entitled “The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners.” The two posts raise important questions about practitioners’ ethical responsibilities when confronting clients’ potential exposure to penalties for failing to file
As part of Kostelanetz’s commitment to pro bono work and giving back to the tax community, on December 5, 2022, Kostelanetz sponsored the New York County Lawyers Association’s (NYCLA) Tax Court Calendar Call Pro Bono Program. NYCLA’s U.S. Tax Court Calendar Call Pro Bono Program matches attorneys with unrepresented taxpayers
Megan L. Brackney participates in a tax litigation and controversy panel on November 22, 2022 at the 2022 Fall Tax Conference co-sponsored by the Wall Street Tax Association and the Wall Street Tax Educational Corporation. Panel Description: Panelists discuss implications of the recent decision on agencies’ regulatory power as well
