Kostelanetz attorneys will be speaking on various panels at the American Bar Association’s 2024 Criminal Tax Fraud and Tax Controversy Conference, which is being held from Dec. 12-14, 2024, in Las Vegas.

As esteemed panelists, our lawyers will demonstrate their experience and knowhow on topics ranging from defense of high-wealth taxpayers and ethical considerations in criminal tax investigations to the current state of the IRS Voluntary Disclosure Program, the legal landscape for Syndicated Conservation Easements, and how the legal profession can promote diversity in its ranks.

Attendees can earn CLE credit throughout the conference. The full conference is eligible for 14.75 hours of CLE in 60-minute states (17.70 in 50-minute states like New York). The conference website can be found here.

Please join us for the following panels.

Friday, Dec. 13 — 9:15 AM – 10:15 AM

Defending High-Wealth Taxpayers In Civil And Criminal Tax Enforcement

Partner Bryan Skarlatos will participate in a panel of highly experienced practitioners, who will address how to be ready for the substantive and procedural issues that may arise in enforcement cases against high-wealth taxpayers, including a discussion of the importance of understanding the bigger picture in which a high-wealth client may operate. The IRS has identified these types of cases as an enforcement priority.

Other participants include moderator Charles P. Rettig, Chamberlain Hrdlicka, and panelists Sheri Dillon, Morgan, Lewis & Bockius LLP; Charles Hodges, Jones Day; and Matthew Lerner, Sidley Austin LLP.

Friday, Dec. 13 — 11:30 AM – 12:30 PM

How Not To Be A Witness Against Your Client: Ethical And Other Considerations In Criminal Tax Investigations (Ethics CLE)

Partner Jay Nanavati will participate in a panel that will explore questions such as, what happens if your proffer in a criminal investigation turns out to be based on erroneous information from your client? What do you do when the grand jury subpoena calls for the client’s records, but those records are, in fact, fraudulent? The panel will discuss how to avoid these pitfalls and the ethical issues that arise when difficult choices must be made.

Other participants include moderator Patricia A. Pileggi, ArentFox Schiff, and panelists Tino Lisella, Carlton Fields; Jeffrey Neiman, Marcus Neiman & Rashbaum LLP; and Rod Rosenstein, King & Spalding LLP.

Friday, December 13 — 1:45 PM – 2:45 PM

“Voluntary Disclosure: Where Are We Now?”

Partner Michael Sardar will participate in a panel addressing the current state of voluntary disclosure programs and their effectiveness in aiding clients with tax compliance. The discussion will cover the evolution of these programs, the future of silent disclosures, and recent changes to the IRS’s voluntary disclosure practice. The panel will also share strategies on how to assist taxpayers in navigating the revised IRS Voluntary Disclosure Practice.

Other participants include moderator Larry Campagna, Chamberlain Hrdlicka, and speakers Dan Price, Law Offices of Daniel N. Price; and Zhanna Ziering, Moore Tax Law Group.

Friday, Dec. 13 — 5:00 PM – 6:00 PM

How The Legal Community Can Focus On Diversity Within Firms And In Service To Our Clients (Elimination of Bias CLE)

Partner Caroline Ciraolo will moderate a panel discussion on the importance of diversity and inclusion within law firms and the legal profession, so that firms can better assist clients in addressing their needs in navigating challenges in addressing their tax issues. Diversity comes in many forms, including national or cultural origin and visible and nonvisible health and physical limitations, as well as more commonly recognized differences in race, gender, sexual identity, sexual orientation, and myriad others. This panel will address how to be more aware of diversity challenges, including, as examples, language or physical barriers, and what resources are available at the IRS and Tax Court to help lawyers meet these challenges. The panel will be introduced by Kostelanetz associate Abigail Burke.

Other participants include panelists Erin M. Collins, National Taxpayer Advocate, IRS Taxpayer Advocate Service; Hon. Maurice B. Foley, Judge, United States Tax Court; and Michael Eddison Romero, Taylor Nelson Amitrano LLP.

Saturday, Dec. 14 — 11:00 AM – 12:00 PM

Conservation Easements: The Year In Review, And What To Expect

Partner Andy Steigleder will moderate a panel on the IRS’s continued focus on conservation easement issues. We have seen criminal and civil trials, with more to come. The panel will discuss key decisions over the past year and what is likely on the horizon.

Other participants include speakers Niles A. Elber, Caplin & Drysdale; Brian Gardner, Asbury Law Firm; Sarah Green, Dentons; Byung Hyuk (Billy) Min, Agostino & Associates P.C.; Carneil Wilson, Dentons.