By Ian Weinstock and Heather Fincher For nearly thirty years, taxpayers have been waiting for the IRS to issue regulations related to foreign trusts and foreign gifts. Since 1996, when Congress enacted a myriad of provisions to prevent tax avoidance through the use of foreign trusts and gifts, taxpayers have
Daniel C. Davidson was quoted in a February 14, 2024 Law360 article titled “First Purely Tax Crypto Indictment Signals More On Tap” on the financial activities likely to capture the IRS criminal unit’s attention in the crypto sphere. The article discusses possible implications of the Department of Justice’s early February
Kostelanetz attorneys will participate in a variety of panels and presentations at the American Bar Association Tax Section’s 2024 Midyear Tax Meeting in San Francisco, CA on January 18-20, 2024. Thursday, January 18, 2024 1:30 PM – 2:30 PM (PST): Andrew Weiner participates in a panel titled “Equitable Tolling and
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Last week, partners and associates from Kostelanetz attended the American Bar Association’s 40th Annual National Institute on Criminal Tax Fraud and the 13th Annual National Institute on Tax Controversy. Partners Bryan C. Skarlatos, Caroline D. Ciraolo, Megan L. Brackney, and Michael Sardar, along with Director of Investigations Don Fort, each led panels
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
