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60th Annual Hawaii Tax Institute Conference
November 5, 2023 - November 9, 2023
Caroline D. Ciraolo and Don Fort present on several panels at the 60th Annual Hawaii Tax Institute Conference in Honolulu, Hawaii on November 5-9. CLE credit is offered for this event.
Monday, November 6
4:00 pm – 4:45 pm (HST): Don Fort participates in a panel titled “Understanding the Sandbox that All Wealth Transfer Advisors Play In” on Monday, November 6 from 4:00 pm – 4:45 pm (HST) / 10:00 pm – 10:45 pm (EST).
Event Description:
The lines are drawn and all Wealth Transfer Advisors need to understand when “planning”
becomes a conspiracy or a crime. This session discusses the latest trends and updates on
Criminal Tax and the IRS’s Priorities, Cryptocurrency Updates and Developments, IRA 2023
Dirty Dozen, Impacts of the Inflation Reduction Act (IRA) on IRS operations and much more.
Panelists:
Don Fort, Director of Investigations, Kostelanetz LLP
Sandra R. Brown, Principal, Hochman Salkin Toscher Perez PC
Guy Ficco, Deputy Chief, IRS Criminal Investigation
Rebecca Perlmutter, Assistant U.S. Attorney
Tuesday, November 7
8:00 am – 9:00 am (HST): Caroline D. Ciraolo participates in a panel titled “Planning, Audit, and Litigation: Using Valuation Discounts to Transfer Wealth” on Tuesday, November 7 from 8:00 am – 9:00 am (HST) / 2:00 pm – 3:00 pm (EST).
Event Description:
Valuation Discounts are the essence of many wealth transfer strategies. This session discusses how valuation discounts are used in planning, what happens if challenged, and how courts evaluate the use of valuation discounts.
Panelists:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Carsten Hoffman, Managing Director, Stout
Andrew M. Katzenstein, Partner, Proskauer Rose
Patrick J. Urda, Judge, United States Tax Court
Wednesday, November 8:
1:30 pm – 2:20 pm (HST): Caroline D. Ciraolo participates in a panel titled “Left Holding the Bag: Withholding Agent Current Issues and Traps for the Unwary” on Wednesday, November 8 from 1:30 pm – 2:20 pm (HST) / 7:30 pm – 8:20 pm (ET).
Event Description:
The global marketplace and increased individual mobility has created additional scenarios where U.S. taxpayers are sending payments outside the United States, thereby making them subject to U.S. withholding and reporting requirements. IRS LB&I has a compliance campaign to examine taxpayers who make such payments but fail to meet their compliance obligations. This session will identify the subset of taxpayers (withholding agents) who are responsible for withholding U.S. tax on payments to foreign payees, explain the surprising way withholding agents can become liable for tax due on money paid to others, and describe how the IRS is holding U.S. withholding agents accountable for the tax liabilities of foreign payees.
Panelists:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Kurt K. Kawafuchi, Managing Member, Law Offices of Kurt Kawafuchi, LLC
Michael Quigley, Partner, Kim & Chang
Thursday, November 9
11:30 am – 12:15 pm (HST): Don Fort participates in a panel titled “Employee Retention Credit Audits and Investigations – The Tsunami is Coming” on Thursday, November 9 from 11:30 am – 12:15 pm (HST) / 5:30 pm – 6:15 pm (EST).
Event Description:
Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. Almost
everyone has seen a commercial or received a text or email offering easy money through
ERC claims. With its inclusion of erroneous and fraudulent ERCs in the IRS’s 2023 list of
“Dirty Dozen” schemes, the IRS has made no secret of its plans to aggressively audit ERC
claims and punish abuse and fraud. This session will discuss the IRS’ targeted enforcement
efforts, explains how to spot red flags indicating abuse of the ERC, and describe the civil
and criminal penalties that can apply to taxpayers, promoters and practitioners for erroneously
claiming ERC credits.
Panelists:
Don Fort, Director of Investigations, Kostelanetz LLP
Sandra R. Brown, Principal, Hochman Salkin Toscher Perez PC
Kathy Enstrom, Director of Investigations, Moore Tax Law Group LLC
Victor S.O. Song, Former Chief, IRS Criminal Tax Division
