Kostelanetz attorneys Michael Sardar, Melissa Wiley, Andy Weiner, and Will Greco will participate on various panels at the 49th Annual Federal Bar Association Tax Law Conference, of which Kostelanetz is a proud sponsor. Kostelanetz partner Caroline Ciraolo will make keynote remarks at the March 3 luncheon.

During the conference, our attorneys will demonstrate their knowledge and experience in ethical issues in taxation, criminal tax matters, navigating tax administration in a post-Chevron and post-Jarkesy landscape, and more.

Virtual portions of the Federal Bar Association Tax Law Conference will be held February 27-28, 2025. In-person sessions will be held on March 3, 2025, at the Ronald Reagan Building & International Trade Center in Washington, D.C. You can learn more about the conference and register here.

Please join us for the following panels:

Thursday, February 27, 2025, 11:00 a.m. to 12:00 p.m. (Virtual Only, Zoom)

Update on Ethical Issues in Taxation and Circular 230

Kostelanetz attorney Melissa Wiley will participate in a panel of experienced practitioners who focus on ethics and conflicts of interest in federal taxation matters. The panel will cover ethical considerations and responsibilities in light of updates to ABA model rules, state bar rules, and other standards that affect practitioners.

Other participants include Christopher Whitcomb, managing director of KPMG LLP, and Matthew Cooper, principal at Deloitte Tax LLP, who is also moderating the panel.

Thursday, February 27, 2025, 12:30 p.m. to 1:30 p.m. (Virtual Only, Zoom)

Developments in Penalty Controversy and Litigation

Kostelanetz attorney Will Greco will participate in a panel covering important developments in (1) IRS practice in the assertion of penalties, including automatic assessment, transfer pricing, economic substance and excessive refund penalties and (2) litigation regarding various penalties, including Farhy limitations on the assessment of certain penalties, 8th Amendment limitations on FBAR and potentially other penalties, and Jarkesy and 7th Amendment considerations in the tax penalty context.

Other participants include Joy Williamson, partner at Baker & McKenzie LLP, and Ed Froelich, counsel at McDermott Will & Emery, who is also moderating the panel.

Monday, March 3, 2025, 10:45 a.m. to 11:45 a.m. (In Person Only)

What Tax Lawyers Need to Know About the APA in Our New Post-Chevron World

Kostelanetz attorney Andy Weiner will moderate a panel discussing the potential impacts of the Loper Bright Supreme Court case on tax law. Participants will discuss the background of Loper Bright and the APA, what practitioners can expect for various tax rules’ levels of deference post-Chevron, and how Congress can delegate authority.

Other participants include David Foster, partner at Kirkland & Ellis LLP, Aaron Junge, international tax partner at PwC, Arvind Ravichandran, partner at Cravath, Swaine & Moore LLP, and Susan Ryba, partner at McDermott Will & Emery.

Monday, March 3, 2025, 11:45 a.m. – 1:30 p.m. (In Person Only)

Keynote Remarks by Caroline Ciraolo

 Kostelanetz partner Caroline Ciraolo will deliver the keynote address during the luncheon program.

Monday, March 3, 2025, 4:00 p.m. to 5:00 p.m. (In Person Only)

When Tax Enforcement Becomes Criminal

Kostelanetz attorney Michael Sardar will co-host a panel on the factors that influence whether IRS criminal investigation agents will seek criminal prosecution. The panel will discuss what IRS-CI agents look for and what the DOJ’s tax division considers when pursuing criminal prosecution, along with the latest trends in criminal tax enforcement.

The panel will be co-run and moderated by Rick Lunger, Division Counsel (Criminal Tax), Office of the Chief Counsel, IRS, U.S. Department of the Treasury.

Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors.  He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.

Melissa comes from an actuarial background that grants her a deep understanding of statistics, professional standards, and collaboration with technical, legal, and forensic professionals. Melissa was an assistant general counsel at a Big Four accounting firm with litigation experience in US Tax Court, Court of Federal Claims, and various federal district courts. She focuses her practice on tax controversies, IRS appeals, and representing clients facing government investigation.

Andy focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. He is also a fellow of the American College of Tax Counsel, and a frequent writer and speaker on tax issues.

Will has clerked for the Honorable Mark V. Holmes of the United States Tax Court. He worked on cases concerning the valuations of real property, due process in collections, and complex tax evasion schemes. Will works with clients preparing offers in compromise, requests for audit reconsideration, and other individual representation matters.