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
In a recent Tax Notes article by Nathan J. Richman entitled “Work-From-Home Technology Comes With New Privilege Concerns,” Paul Butler discussed concerns about how to safeguard attorney-client privilege and protect the work product doctrine when using videoconferencing and other new technological tools that tax professionals are relying on during the coronavirus
This panel discussed the rules protecting communications from disclosure, using real-world examples. The panelists also discussed hot topics and best practices. Panelists: Paul Butler, Kostelanetz & Fink, Washington, DC; Abbey Barber, Thompson Knight, Dallas, TX; Peter K. Reilly, Special Counsel, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC
For years, wrongfully incarcerated individuals who received compensation for their time behind bars were required to pay income taxes on the settlements they received from government organizations responsible for their wrongful incarceration. Congress changed the law in 2015 to exempt exonerees from paying income taxes on civil damages, restitution or
In 2018, the California Supreme Court approved a comprehensive re-write of its rules of professional conduct. California has now joined the other 49 states in adopting ethics rules patterned after the ABA Model Rules of Professional Conduct, effective November 1, 2018. The rules are binding on all attorneys licensed by
Statutes of limitations are an important, but often overlooked, aspect of tax litigation that can work to the advantage or the detriment of a party. Most practitioners are familiar with the general three-year period of limitation on assessment, as well as basic exceptions, including those for a false return, no
The contours of various privileges (attorney-client, attorney work product, spousal, etc.) vary from one jurisdiction to another domestically from whether each privilege exists to who holds (or “owns”) the privilege to how it is waived or preserved. Putting those issues into cross-border transactions and negotiations conducted through a variety of
