Cross-Border Real Estate Investments
2025-02-17 - 2025-02-18
Counsel Eduardo Cukier will speak at the 2025 International Tax Conference hosted by the University of San Diego School of Law and Chamberlain Hrdlicka Law Firm.
Eduardo’s panel, “Cross-Border Real Estate Investments,” will be held on Tuesday, February 18, from 11:15 a.m. to 12:05 p.m. The panel will discuss U.S. and Mexican tax and other considerations of cross-border real estate investments between the U.S. and Mexico. Eduardo will be joined by Patrick W. Martin of Chamberlain Hrdlicka and Rodrigo Adam of HgL Asesores.
The 2025 International Tax Conference will be held at Centro Internacional de Congresos (CIC) in Mérida, Yucatán, México on February 17-18, 2025. Sessions and panels will cover a variety of business, personal, and fiduciary cross-border taxation issues such as cross-border financing, international tax controversies, foreign tax credits, tax treaty considerations, and more. Kostelanetz partner Caroline Ciraolo is also a member of the International Tax Conference’s advisory board.
You can learn more about the conference and register here.
Eduardo focuses his practice on international tax issues concerning multinational businesses and high-net-worth clients. Having many years of experience with taxation and legal frameworks in both the U.S. and Latin America, Eduardo works with both domestic and multinational clients from a wide range of industries on foreign and domestic mergers and acquisitions, business restructuring, and cross-border litigation.

2025 ABA Tax Section Mid-Year Meeting
2025-02-19 - 2025-02-21
Kostelanetz attorneys Michael Sardar, Bryan Skarlatos, and Andy Weiner will speak on various panels of the ABA Tax Section Mid-Year Meeting, of which Kostelanetz is a Diamond sponsor. Our attorneys will demonstrate their knowledge and experience in international tax controversies and other international taxation matters, criminal tax cases, refund litigation, and more.
The ABA Tax Section Mid-Year Meeting will be held February 19-21, 2025, at the JW Marriott LA LIVE event center in downtown Los Angeles. The conference covers a large array of tax law topics and updates from the nation’s leading tax attorneys and authorities. You can learn more about the event and register here.
Please join us for the following panels:
Thursday, February 20, 2025, 10:00 a.m. to 11:45 a.m.
Cross-Functional Current Developments – Part II
Kostelanetz partner Bryan Skarlatos will participate in a panel in the conference’s Corporate & International Track discussing the latest regulatory and case law developments in corporate and individual international taxation. The panel will cover contemporary international tax issues, transfer pricing, and the increasing relevance of the economic substance doctrine in the U.S.
Other participants include Hans Gerling of KPMG; Professor Adam M. Katz of Seton Hall University School of Law; Loren Ponds of Skadden; and Jennifer R. Noel of ChristianaCare, who is moderating the panel.
Friday, February 21, 2025, 8:30 a.m. to 10:15 a.m.
Hot Topics and Common Pitfalls in Refund Litigation
Kostelanetz counsel Andy Weiner joins a panel that will explore the complexities of refund litigation for the conference’s Controversy Track. Panelists will discuss the considerations practitioners must make, and pitfalls they are likely to encounter, in litigating claims for refunds and abatements. Current refund litigation trends will also be discussed, including claims made under the Employee Retention Credit.
Other panelists include Melissa Briggs of Hochman Salkin Toscher Perez P.C.; Jeff Glassman of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP; Gavin Greene from the U.S. Attorney’s Office for the Central District of California; and M. Blair Hlinka of Caplin and Drysdale, Chartered, who is moderating the panel.
Friday, February 21, 2025, 10:30 a.m. to 12:15 p.m.
Keeping it Civil: How to Prevent a Civil Matter from Turning Criminal
Kostelanetz partner Michael Sardar will moderate a panel for the conference’s Controversy Track, discussing how to identify civil tax cases that could potentially become criminal matters. The panel will discuss criteria that often trigger criminal referrals, ethical considerations and strategies for such situations, and common pitfalls that practitioners face when civil matters are at risk of becoming criminal.
Other participants include Jenny C. Lin of Lin Tax Law; John Marston of Sheppard Mullin; Richard Westling of Epstein, Becker & Green, P.C.; and Zhanna A. Ziering of Moore Tax Law Group LLC.
For more than thirty-five years, Bryan has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice.
Michael has extensive experience on a wide range of tax controversy and white-collar criminal defense matters. 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.
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.

IRS Administrative Affairs: Current Developments and Reading the Tea Leaves in Tax Enforcement
2025-02-26
On February 26, 2025, Caroline Ciraolo will speak to Tax Executives Institute’s Detroit Chapter in Levonia, Michigan, about civil tax controversies, including current developments and expectations for tax enforcement in 2025 and beyond. Caroline will present with David Lee with National Tax Controversy Services, Deloitte LLP, who will address IRS administrative affairs and issues facing domestic and multinational entities, including transfer pricing.
Other panelists presenting to the TEI Detroit Chapter on topics including U.S. trade policies include Becky Allen LCB CUSECO, Senior Manager, Global Trade Advisory, Deloitte LLP, and David Reichow, Managing Director, Global Transfer Pricing, Deloitte LLP.
Two hours of CPE credit is available for this program.
Click here for more information and to register. Registration ends at 6 p.m. Thursday, February 20, 2025.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice 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, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

49th Annual Federal Bar Association Tax Law Conference
2025-02-27 - 2025-03-03
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.
