On September 8, 2023, the IRS announced a “sweeping effort” to target America’s wealthiest taxpayers. IRS Commissioner Daniel Werfel described enforcement actions, which will be funded by the Inflation Reduction Act of 2022 and will include the scrutiny of returns filed by 75 partnerships with over $10 billion in assets; 500 partnerships
IRS Also Forecasts ERC Settlement Program On September 14, 2023, IRS Commissioner Danny Werfel ordered an immediate moratorium on the processing of Employee Retention Tax Credit (“ERC”) claims. According to the IRS, the moratorium will be in place through at least December 31, 2023. The moratorium is the IRS’s boldest step
Caroline D. Ciraolo and Director of Investigations Don Fort recently attended the 40th Cambridge International Symposium on Economic Crime held at Jesus College in Cambridge University. The two delivered keynotes and moderated panel discussions about some of the biggest challenges in financial crime cases today. On September 3, Don delivered
NEW YORK (September 5, 2023) — Kostelanetz LLP has been recognized by International Tax Review/World Tax as a top-tier firm for tax controversy in the publication’s 2024 rankings guide. Additionally, four of the firm’s partners have been recognized as “Highly Regarded” tax controversy practitioners. Both the New York and Washington, D.C.
By Caroline Ciraolo, Don Fort, and Ian Weinstock Bloomberg Tax August 28, 2023 High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the
Caroline D. Ciraolo was quoted in a Tax Notes article titled “IRS Penalty Practice May Be Due for Reset,” published on August 16, 2023. The article addresses the current state of penalty administration and notes Caroline Ciraolo’s concerns regarding the Internal Revenue Service’s current approach to the consideration and assessment
Caroline Ciraolo Also Selected ‘Lawyer of the Year’ NEW YORK (August 17, 2023) — Thirteen Kostelanetz attorneys, including all ten partners, have been recognized by “Best Lawyers in America®” in the 2024 edition, and Caroline D. Ciraolo has been named “Lawyer of the Year” for Litigation and Controversy – Tax
As part of a broader effort reflected by the Corporate Transparency Act to combat the use of shell companies for illicit purposes, the Financial Crimes Enforcement Network within Treasury, or FinCEN, issued FinCEN Notice FIN-2023-NTC1 (Aug. 15, 2023) designed to promote reporting by U.S. financial institutions regarding payroll tax evasion and workers’
On Tuesday, September 5th, 2023, Caroline D. Ciraolo presents a keynote address titled “The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement” at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge. Date: 8:00am BST (U.K. Time) on Tuesday September 5th, 2023. A full
On August 15th, 2023, Caroline Ciraolo participates in a webinar panel titled “IRS Penalty Policy and Practice” as part of a webinar series titled “Transforming Tax Administration” presented by Center for Taxpayer Rights. Description: Center for Taxpayer Rights presents a series of webinars from March 23, 2023 through August 31,
