Megan L. Brackney and Melissa Wiley will participate in an in-depth session on current tax penalty issues at the Advanced International Taxation Conference sponsored by the New York University (NYU) School of Professional Studies.

The panel will be held July 18, 2025, from 3:15 p.m. to 4:30 p.m. Conference agenda and registration information can be found here.

July 18, 2025, 3:15 p.m. – 4:30 p.m.

Current Penalty Issues

Megan and Melissa will participate in a panel that will delve into the complex filing requirements for international information returns and the often life-altering penalties imposed for noncompliance.  As a result of the IRS’s increased focus on enforcement in this area in recent years, many taxpayers have challenged international information return penalties on various technical grounds and on the basis of reasonable cause. Recently, some of these challenges have been addressed by the courts. This session will discuss recent cases in the area as well as their implications going forward.

 Other panelists include: Victor A. Jaramillo, Esq., Member, Caplin & Drysdale, Washington, DC; and Larry A. Sannicandro, Esq., Partner, Pillsbury Winthrop Shaw Pittman, New York, NY

NYU notes that the Advanced International Taxation Conference provides sophisticated knowledge of “hot button” issues and opportunities in international taxation such as:

• Planning and pitfalls applicable to doing business globally, including the use of hybrid US and foreign entities and investment structures
• Planning and structuring issues involving cross-border mergers and acquisitions
• Eligibility issues under US income tax treaties
• Foreign investment in US real estate property and US taxpayers’ investments in foreign real estate
• Drafting intercompany agreements with an eye on transfer pricing

About Megan

Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. The current Chair-Elect of the American Bar Association Section of Taxation, she is also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.

About Melissa

With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights, helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Prior to becoming an attorney, Melissa worked in the insurance industry as an actuarial analyst.