Tax Talks

The Proskauer Tax Blog

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Abraham Gutwein

Abraham Gutwein is a senior counsel in the Tax Department. Abe devotes a substantial part of his time to the resolution of tax controversies and advising on the tax aspects of bankruptcy reorganizations.

Abe has advised numerous corporate and individual clients on a broad range of substantive and procedural issues that have arisen during the course of federal, state and local tax disputes, and has participated in the litigation and settlement of many such disputes at the audit and administrative levels and before the courts.

In addition, Abe frequently counsels a broad range of clients on sales tax issues, as well as being involved in all aspects of Proskauer's general tax practice.

Abe advises clients about the complex tax issues that often arise in the course of bankruptcy restructurings, including cancellation of debt income, net operating losses, original issue discount and the operation of the “priority” rules governing governmental tax claims.

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Extension of FBAR Filing Deadline for Certain Filers

On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2022. FinCEN has provided … Continue Reading

Extension of FBAR Filing Deadline for Certain Filers

On December 20, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2019-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2021. FinCEN has provided … Continue Reading

Extension of FBAR Filing Deadline for Certain Filers

On December 4, 2018, FinCEN issued Notice 2018-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2020. FinCEN has provided similar extensions over the previous … Continue Reading

Impact of Recent Tax Legislation on M&A Transactions

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions.  Some of these rules are very complex, particularly in cross-border transactions, and this post describes them in general terms without all of their fine details.  The discussion of foreign … Continue Reading

Extension of FBAR Filing Deadline for Certain Filers

As noted in our January 5, 2017 client alert, FinCEN issued Notice 2016-1, which extends the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2018. Please click … Continue Reading
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