In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et al. v. United States, Case
As reported in our last news alert, the IRS is moving aggressively to investigate Malta Pension Plans. This is after naming Malta Pension Plans to the IRS’s Dirty Dozen (its annual list of abusive transactions), issuing a Competent Authority Arrangement walking back the tax benefits otherwise allowed under the U.S.-Malta
Malta Pension Plan arrangements under the United States-Malta Income Tax Treaty are a top enforcement priority of the IRS, finding their way onto the annual Dirty Dozen list. Yesterday, the IRS intensified its efforts as Special Agents from IRS Criminal Investigation (IRS-CI) descended on numerous participants in the Malta Pension
NEW YORK (June 2, 2023) —Chambers and Partners has once again recognized Kostelanetz LLP and five partners in its 2023 USA Guide in the areas of tax controversy, tax fraud, tax law, and white-collar defense and government investigations. Chambers USA ranks the top lawyers and law firms across the United States of America through an assessment
In a unanimous opinion delivered by Chief Justice John Roberts on May 18, 2023, the Supreme Court ruled that the Internal Revenue Service was not required to notify an individual and two law firms of summonses seeking their banking records. In the matter of Polselli et al. v. Internal Revenue
On May 25, 2023, Don Fort presents on the AML Rightsource Voices Webinar titled “Private-Public Partnerships and how they enhance detection, prevention, and reporting of financial crime.” Description: The AML/Sanctions/CFT community has long embraced partnerships and collaboration. This edition of AML Voices will focus on the value of these partnerships
On May 30, 2023, Don Fort appears on the Center for Taxpayer Rights’ Tax Chat! Series on Transforming Tax Administration in an episode entitled “Tax Chat on Big Data and AI in Tax Administration.” Participants: Host: Nina Olsen, former National Taxpayer Advocate Guest: Don Fort, Kostelanetz LLP Click here for
Caroline Ciraolo Also Selected As A Leading Tax Lawyer in DC WASHINGTON, D.C. (April 26, 2023) – Super Lawyers has selected Jay R. Nanavati as one of its “Top 100” Washington DC Super Lawyers for 2023. Nanavati is ranked as a top white-collar criminal defense attorney by the rankings agency, but
On April 27, 2023, Christopher M. Ferguson leads a presentation entitled “The Next Wave of IRS Enforcement? Employee Retention Credit Fraud” with Celesq. Description: This presentation will discuss the latest burgeoning area of pandemic relief fraud enforcement: the Employee Retention Credit. Topics that will be covered include: What the Employee
