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American Bar Association Tax Section 2024 Midyear Tax Meeting
January 18 - January 20
Kostelanetz attorneys will participate in a variety of panels and presentations at the American Bar Association Tax Section’s 2024 Midyear Tax Meeting in San Francisco, CA on January 18-20, 2024.
Thursday, January 18, 2024
1:30 PM – 2:30 PM (PST): Andrew Weiner participates in a panel titled “Equitable Tolling and Tax Collections.”
Description: This panel will focus on equitable tolling and how it applies to requests for collection due process hearings and in the Tax Court.
Moderator:
Goldburn P. Maynard, Jr., Loretta Argrett Fellow, Assistant Professor, Indiana University, Kelley School of Business
Panelists:
Andrew Weiner, Counsel, Kostelanetz LLP
Jonathan Kalinski, Shareholder, Hochman, Salkin, Toscher, Perez P.C.
Christopher Jones, Senior Technician Reviewer, Procedure & Administration (Branch 4), IRS Office of Chief Counsel
2:00 pm – 3:00 pm (PST): Michael Waalkes participates in a panel titled “Employee Retention Credits: Overview and Audit Risks”
Description: This panel will provide an overview of the background and evolution of the “employee retention credits,” first introduced with the CARES Act. Panelists will address recent IRS announcements acknowledging potentially fraudulent employee retention credit schemes and erroneous claims for such refunds, and the impact of heightened audit risks for companies, including in M&A transactions.
Panelists:
Michael Waalkes, Associate, Kostelanetz LLP
Greg A. Chriss, PwC U.S. Tax LLP
Jimmy B. Franco, Indirect Tax Manager, Ernst & Young LLP
Andrew L. Gradman, Partner, Falcon Rappaport & Berkman LLP
Rami M. Khoury, Associate, Taylor Nelson Amitrano LLP
6:00 PM – 7:30 PM (PST): Michael Waalkes participates in a panel titled “Careers in Tax.”
Description: This panel will open a discussion between current practitioners in the tax law space to provide information for L.L.M. or J.D. students seeking a career in tax.
Moderator:
Janelle N. Darnell, Associate, McGuireWoods LLP
Panelists:
Michael Waalkes, Associate, Kostelanetz LLP
Marc D. Nickel, Associate, McGuireWoods LLP
Sean Silva, M&A Tax Sr. Manager, KPMG LLP
Lany L. Villalobos, Associate, Kirkland & Ellis LLP
Friday, January 19, 2024
4:00 PM – 4:55 PM (PST): Andrew Weiner participates in a panel titled “Defining Refund Litigation When the Refund Claim is Filed.”
Description: Refund litigation is likely to increase as the IRS summarily denies refund claims through its Service Centers or plainly refuses to process other types of refund claims, such as those involving the employee retention credit. The scope of the refund litigation is defined when the refund claim is administratively filed with the IRS. The panelists will discuss best practices for filing administrative refund claims, including how to navigate: statutes of limitation considerations; the specificity requirements; the doctrine of variance; protective claims for refund; and more.
Moderator:
Garrett L. Brodeur, Associate, Skadden, Arps, Slate, Meagher & Flom LLP
Panelists:
Andrew Weiner, Counsel, Kostelanetz LLP
Pamela Grewal, Managing Director, Andersen
Christopher Jones, Senior Technician Reviewer, Procedure & Administration (Branch 4), IRS Office of Chief Counsel
Saturday, January 20, 2024
9:30 AM – 10:30 AM (PST): Maxwell Brown participates in a panel titled “Strategical Issues in the Evolving ERC Area.”
Description: Panel will discuss the moratorium and strategical issues taxpayers should consider moving forward in an uncertain enforcement environment.
Moderator:
Mary Wood, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
Panelists:
Maxwell Brown, Associate, Kostelanetz LLP
Tony Box, Partner, Gray Reed
