The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil
2024-11-12 13:50 - 15:30 (America/Los_Angeles)
Kostelanetz LLP partner Michael Sardar will lead a session at the 2024 Taxpayer Representation Super Conference, hosted by the American Society of Tax Problem Solvers (ASTPS), from November 12-14, 2024, at Embassy Suites San Antonio Riverwalk. Michael’s session, “The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil,” on November 12 from 1:50 pm to 3:30 pm will focus on managing risk in large and complex IRS audits, where large adjustments are likely. He will guide attendees through strategies for preserving clients’ privileges during sensitive audits, recognizing signs that an audit could escalate to a criminal investigation and ensuring clients remain compliant with their tax reporting obligations.
The Super Conference, a three-day event dedicated to representing clients before the IRS, features 15 sessions on high-level tax resolution topics. Attendees, including practitioners who focus on criminal and civil tax matters, white-collar criminal defense and government investigations, and tax controversy, will learn about issues ranging from criminal tax investigations to tax controversy litigation.
As IRS enforcement is expected to increase in 2025, the conference provides timely insights. Other notable sessions include how to file a protest letter to appeal denied Offers in Compromise, the IRS’s use of AI in auditing high-income taxpayers, and strategies for handling cases led by newly hired IRS agents.
You can learn more about the ASTPS Super Conference and register here. While live attendance in San Antonio is currently waitlisted, virtual attendance options are still available.
Michael Sardar is an experienced tax attorney and co-chair of the Federal Bar Association’s section on taxation’s New York chapter. Michael has vast experience in IRS foreign bank and asset reporting (FBAR) requirements and the IRS Offshore Voluntary Disclosure Program. He represents a variety of clients in civil and criminal tax investigations and prosecutions and other white-collar criminal matters in New York State and New York City.

"Winning Business in New York" panel during City & State New York’s Government Procurement Conference
2024-11-14 10:45 - 11:40 (America/New_York)
On November 14th, 2024, Usman Mohammad will be speaking on a panel titled, “Winning Business in New York,” during City & State New York’s Government Procurement Conference: Optimizing Costs, Mitigating Risks, & Enabling Business Growth. The Government Procurement Conference will foster business partnerships between the city and state level government, prime contractors, and small, minority, service-disabled veteran-owned, veteran-owned, and women-owned businesses.
Panel Description:
This panel offers a detailed discussion about the New York procurement process and finding ways to succeed. What are the most effective strategies addressing challenges including the possibility of an economic downturn, methods to winning the bidding process, and making sense of various kinds of RFPs, plus you will hear what NY government entities want from potential contractors.
Moderator:

Carlo Scissura, President, New York Building Congress

Panelists:

Usman Mohammad, Counsel, Kostelanetz LLP
Roman Gofman, Deputy Commissioner, NYC Office of Citywide Procurement
Lisette Camilo, Chief Administrative Officer, Metropolitan Transit Authority
Marc Hiller, General Counsel and Director of Procurement Services, Ostroff Associates, Inc.

Additional information on the event, including registration, is available here.

Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know (CLE)
2024-11-15 13:15 - 14:15 (America/Chicago)
On November 15, 2024, Megan L. Brackney will co-moderate a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” as part of the Practising Law Institute’s “Tax Strategies 2024 – Chicago” programming. Attendees will receive the latest information, strategies, and practical insights available from leading tax practitioners across the United States, along with policymakers from the IRS and the Department of the Treasury.
Course Description:
This panel will focus on the various judicial doctrines and ethical issues that arise in the corporate tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on corporate transactions, including standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions.
Respond to the IRS in an audit.

Moderators:

Megan L. Brackney, Kostelanetz LLP, New York City
Jennifer E. Breen, Morgan, Lewis & Bockius, Washington, D.C.

For full program details and registration information, please click here.
CLE credit is available for this event.

Ethics in Tax: Standards for Tax Advice
2024-11-21 09:00 - 09:55 (America/Los_Angeles)
Kostelanetz LLP partner Megan L. Brackney will kick off the Committee of Banking Institutions on Taxation (CBIT) 2024 Fall Tax Day with a session on November 21, 2024, from 9:00-9:55 AM on ethical standards for dispensing tax advice. Known for her extensive knowledge of tax ethics, Megan regularly educates other tax professionals on how to navigate the complexities of ethical issues in tax practice. Her session will be a valuable opportunity to explore current tax challenges while ensuring adherence to the highest ethical standards.
Fall Tax Day will take place at Arno Ristorante in New York City. The event begins at 8:45 AM and includes a full day of sessions covering topics like tax reporting regulations for digital assets, capital gains reporting, among other types of gains, and foreign trusts. Speakers from other prestigious firms such as PwC, Wolters Kluwer, and KPMG will join, along with insights from government professionals.
The cost to attend is $75 for CBIT Education members and $125 for non-members, with discounted rates available for members’ guests. Tax students and public service professionals may be eligible for waived registration fees. A cocktail reception at 4:30 PM concludes the day’s events.
You can learn more about CBIT’s 2024 Fall Tax Day and register here.
Partner Megan L. Brackney is an experienced tax attorney, Chair-Elect of the American Bar Association Section of Taxation, and an adjunct professor at New York University School of Law. Megan is also former Assistant U.S. Attorney for the Southern District of New York and a frequent speaker and contributor at local and national conferences on taxation, ethics in tax practice, penalties, and tax controversy.

Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know (CLE)
2024-12-13 13:15 - 14:15 (America/Los_Angeles)
On December 13, 2024, Andrew Weiner will co-moderate a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” as part of the Practising Law Institute’s “Tax Strategies 2024 – Los Angeles” programming. Attendees will receive the latest information, strategies, and practical insights available from leading tax practitioners across the United States, along with policymakers from the IRS and the Department of the Treasury.
Course Description:
This panel will focus on the various judicial doctrines and ethical issues that arise in the corporate tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on corporate transactions, including standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions.
Respond to the IRS in an audit.

Moderators:

Andrew Weiner, Kostelanetz LLP, Washington, D.C.
Chad D. Nardiello, Nardiello Turanchik Tompkins LLP, Los Angeles

For full program details and registration information, please click here.
CLE credit is available for this event.

Defending Your Client in the Age of Fraud Enforcement: 2025 International Tax Conference Session
2025-01-09 - 2025-01-10
Kostelanetz partner Caroline Ciraolo is a speaker at the 2025 International Tax Conference taking place January 9-10, 2025, in Miami, Florida.
Caroline’s session, “Defending Your Client in the Age of Fraud Enforcement,” covers tax defense strategies for clients with cross-border activity in the wake of ramped-up IRS enforcement activity. She is presenting with Jeffrey Neiman, a founding partner of Marcus Neiman Rashbaum & Pineiro LLP.
The ITC is sponsored by the Florida Bar Tax Section and the Florida Institute of Certified Public Accountants. The conference is designed for tax professionals who focus on international taxation planning and compliance, international tax controversies, and managing multinational clients’ needs.
CLE credit is available. You can learn more about the conference here.
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, 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.

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.

Criminal Tax Enforcement at the ABA 40th Annual White Collar Crime Institute
2025-03-04 - 2025-03-07
Kostelanetz partner Caroline Ciraolo will moderate a panel addressing criminal tax matters at the 2025 ABA 40th Annual White Collar Crime Institute, taking place March 5-7, 2025, in Miami, Florida.
The panel is on Wednesday, March 5, 2025, at 10:30 AM and is titled “The Long and Winding Road – From Civil Fraud Referral to Criminal Tax Indictment.” The panelists will review the lifecycle of a criminal tax case that begins as a civil audit or collection matter, travels through the administrative criminal investigation, is referred to the Justice Department (DOJ) Tax Division, and ends with authorization to prosecute. The panelists will discuss what prompts a fraud referral to IRS Criminal Investigation (IRS-CI), how IRS-CI selects its cases, its investigative tools, the applicable standards of review, role of IRS-CI and DOJ Tax conferences, and charging decisions. The panel will also address current criminal tax enforcement priorities, statistics on criminal tax investigations and prosecutions, and cases ripped from the headline.
The ABA White Collar Crime Institute will be held at the Hyatt Regency Miami. There is also an additional Women in White Collar ticketed luncheon and Q&A. You can learn more about the event and register here.
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.

Gray Proctor Serves as Judge for National Tax Moot Court Competition
2025-03-06 - 2025-03-08
Gray Proctor took up the role of judge for the National Tax Moot Court Competition from March 6-8, 2025 at Stetson University in St. Petersburg, Florida, lending his knowledge and experience to the next generation of tax controversy practitioners.
Gray’s service as a judge is the latest in a long history of service to Floridians. Gray’s tax practice is based out of Kostelanetz’s Atlanta office but he still maintains a separate Florida-centric civil and criminal appellate practice and accepts appointments from federal courts in Florida under the Criminal Justice Act. He is qualified as a board-certified appellate specialist by the Florida Bar Association.
The National Tax Moot Court Competition is hosted by the Tax Section of the Florida Bar. For over 30 years, the event has drawn J.D. and LL.M candidates from around the U.S. to demonstrate their skills in oral arguments and writing briefs. Participants also gain valuable networking opportunities with experienced attorneys to build their tax law careers and gain exposure to variegated tax law practice areas. You can learn more about the competition and stay tuned for 2026 dates here.
About Gray
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal penalties. He also maintains a trial support practice focusing on dispositive motions and other key issues upon which an appeal might follow.

NYU Tax Law Association: Tax Controversy Panel
2025-03-20 13:05 - 14:15 (America/New_York)
Megan Brackney and Eduardo Cukier will participate in a tax controversy panel hosted by the New York University Tax Law Association on March 20, 2025 from 1:05 P.M. to 2:15 P.M.
Megan will moderate the panel, and Eduardo is a speaker. They will join Samantha Rinaldi of Christopher Bryne PLLC; Aaron Esman of Ziering Esman, PLLC; and Fran Obeid of MFO Law PC to discuss the latest developments in tax controversy practice and share their knowledge and experience with NYU Law students.
Megan is an adjunct professor at NYU School of Law, where she teaches courses on tax procedure.
You can learn more about the panel and other NYU Law events here.
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 Eduardo
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, business restructuring, and cross-border litigation.

Tax Controversy 2025: Navigating the New Enforcement Landscape
2025-03-24
Partner Bryan Skarlatos is co-chairing the Practising Law Institute’s (PLI) one-day program, Tax Controversy 2025: Navigating the New Enforcement Landscape, in New York City on March 24, 2025. Bryan will be joined by Michael J. Desmond of Miller & Chevalier as co-chair, and a myriad of experienced practitioners from other law firms and the IRS will present.
This full-day program will feature several panels that explore the nuances of federal tax controversy issues and how to recognize them before they become tax enforcement risks. Bryan and the other practitioners will walk attendees through the IRS examination process all the way from the initial audit plan through closing conferences, the administrative appeals process, Bipartisan Budget Act of 2015 (BBA) audit procedures, and areas in which the IRS is prioritizing enforcement actions.
Panels discussions in the program include:

Handling an IRS Examination: This panel will explore processes such as the initial audit plan, information document requests, summonses, foreign information requests, third-party contacts, privileges, extensions of the statute of limitations and closing conferences.
Unique Tax Controversy Issues Relating to Partnerships: This panel will focus on steps being taken by the IRS to coordinate partnership audits, discuss partnership-related campaigns and other areas of substantive focus, and provide insight into procedural aspects of the BBA rules, including the determination of imputed underpayments, when the modification rules may be useful, how the modification procedures are being implemented, and pitfalls to watch out for with push-out elections.
IRS Enforcement Priorities: The session will identify areas of IRS enforcement, such as high-income cases, partnership issues, digital assets, Reports of Foreign Bank Accounts (FBAR) violations, employment tax issues, and promoted tax shelters. Panelists will address challenges the IRS will face as it endeavors to implement its strategic operating plan, complicated by issues flowing from tax administration in a global economy, including transfer pricing, competing jurisdictional claims for primary taxing rights, and double taxation and increased application of the Administrative Procedure Act to tax regulations and other guidance.
Recent Tax Cases and Pending Litigation: This panel will review a number of pending and recently decided cases, including Moore, Loper Bright, Corner Post, Varian, 3M, Patel, Liberty Global, and Otay.
Valuation and Valuation Disputes in Tax Cases: This panel will provide an overview of valuation concepts as they arise in tax cases, identify areas of common dispute and controversy, and summarize best practices for securing and defending valuations in tax cases.

After completing this day-long program, participants will be able to:

Anticipate potential federal tax controversy issues before they arise
Assist taxpayers in understanding the compliance and enforcement risks associated with uncertain tax reporting positions and in taking steps to mitigate those risks
Effectively resolve issues in the IRS examination and administrative appeal process

The program is designed for tax attorneys, accountants and in-house tax professionals interested in obtaining a broader understanding of the process for handling tax controversy matters in the context of IRS audits and administrative appeal proceedings and key concepts that arise in tax controversy.
The full-day program will take place at PLI’s New York office on 1177 Avenue of the Americas (entrance on 45th Street). Virtual attendance options are also available. You can learn more about the program and register here.
About Bryan
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.

Tax Relief Tactics: Mastering IRS Penalties, Fines, and Interest Abatement
2025-03-27
Kostelanetz counsel Gray Proctor presents a CLE session for myLaw titled “Tax Relief Tactics: Mastering IRS Penalties, Fines, and Interest Abatement.” Gray’s session, titled “Penalty Defense: Reasonable Cause + A Few More,” is the second half of the two-part CLE series co-sponsored by myLaw and the Federal Bar Association. The first session, titled “Correcting Noncompliance and IRS Penalty Relief,” is presented by Phillip J. Colasanto of Withers Bergman LLP.
In Session II, Gray focuses on reasonable cause and the major role it plays in civil tax controversy and white-collar defense strategies. In many cases, reasonable cause is key to receiving tax penalty mitigation from the IRS. Gray’s session dives into the elements of reasonable cause defenses, including the limits of the defense, the role of disclosure and level of certainty in mitigating penalties, and considerations unique to specific penalties, from failure to file to gross valuation misstatements.
Gray also discusses landmark Supreme Court decisions such as Loper Bright and Jarkesy, which could affect how reasonable cause defenses are utilized going forward.
You can learn more about the webinar and register for the recorded session here.
About Gray
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal penalties. He also maintains a trial support practice focusing on dispositive motions and other key issues upon which an appeal might follow.

Choosing the Ethical Path in Tax Matters: IFA US Branch Conference 2025
2025-03-27 - 2025-03-28
Kostelanetz partner Caroline Ciraolo will speak at the 53rd Annual International Fiscal Association (IFA) U.S. Branch Conference, taking place March 27-28, 2025, in Washington, DC.
The session, titled “Not as Easy as it Looks: Choosing the Ethical Path in Tax Matters,” will be held on March 27, 2025, from 4:15 PM to 5:15 PM. You can learn more about the conference and register here. Early bird registration rates end February 28, 2025.
The International Fiscal Association (IFA) states that it is the leading non-governmental international organization handling international tax matters. With a presence in 111 countries, the U.S. branch is one of the largest IFA branches split into 17 regional chapters dedicated to current international taxation issues, international tax controversy, and connecting international tax professionals from multiple countries.
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.

BBA Partnership Audit Rules – Controversy and Procedure
2025-04-01
Partner Megan Brackney will present on “BBA Partnership Audit Rules – Controversy and Procedure” at the Practising Law Institute’s (PLI) Understanding the BBA Partnership Audit Rules 2025 full-day seminar in PLI’s New York City office on April 1, 2025.
Megan’s panel, which is from 11:45 a.m. to 12:45 p.m., will cover how the Bipartison Budget Act of 2015 (BBA) was enacted to make it easier for the IRS to assess and collect tax attributable to adjustments to partnership-related items. As a result, the law has created new procedural rules for partnership audits. The session will discuss the steps in a BBA audit, the role of appeals, practical challenges for partnership representatives, key deadlines for the IRS, how interest calculations may be larger under the BBA, when penalties may apply and what penalty defenses are available. This session will also discuss judicial review and practical issues arising in BBA audits.
Other participants include Jennifer M. Black, Hans F. Famularo (Invited), Kate Kraus, and Lee S. Meyercord.
Virtual and in-person attendance is offered. You can learn more about the seminar and register here.
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan is the current Chair-Elect of the American Bar Association Section of Taxation and also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.

ABA Annual U.S. and Europe Tax Practice Trends Conference
2025-04-09 - 2025-04-11
Kostelanetz attorneys Caroline Ciraolo, Melissa Wiley, and Heather Fincher will speak on various panels at the ABA Tax Section’s 25th Annual U.S. and Europe Tax Practice Trends Conference, of which Kostelanetz is a proud sponsor.
The U.S. and Europe Tax Practice Trends Conference focuses on international tax compliance, international tax controversy matters, and tax practice trends in the international business sphere. Practitioners, international advisers, and government officials will gain a greater understanding of how the current international business and taxation environments affect multinational corporations.
Caroline, Melissa, and Heather have been asked to speak on international tax controversies, criminal tax matters, current trends in tax enforcement, and more.
The conference will take place at Hotel Okura in Amsterdam on April 9-11, 2025. You can learn more about the conference and register here.
Please join us for the following panels:
Wednesday, April 9, 2025, 4:00 p.m. to 5:30 p.m.
Powerhouse Tax Women in the Know: What’s Top of Mind & Navigating 2025
Kostelanetz attorney Heather Fincher, will co-chair a panel with leading women tax practitioners from multinational businesses. The panel will discuss the most pressing international taxation and regulatory issues of 2025.
Other participants include Natalie Reypens of Loyens & Loeff, a fellow co-chair of the panel; Luana Foffo Ciucci, Director, Southern & South East Europe, Procter & Gamble, Rome; Federica Pitrone, Head of International Tax, Intesa Sanpaolo SpA, Milan; Sonja Schiller, Counsel, Alphabet Regulatory Response, Investigations & Strategy, Seattle, WA; and Jenny Wong, Vice President, North American Tax Insurance, Ryan Transactional Risk, New York, NY.
Thursday, April 10, 2025, 4:30 p.m. to 6:00 p.m.
Criminal Tax
Kostelanetz attorney Caroline Ciraolo will co-chair a panel on criminal tax matters and international tax matters.
Other participants include fellow co-chair Sabine Stetter of Stetter Attorneys at Law, Munich; Jeffrey Neiman of Marcus Neiman Rashbaum & Pineiro LLP, Fort Lauderdale, FL; Silvia Martina of Cagnola & Associati Studio Legale, Milan; and Alice Rousseau of Alice Rousseau Avocats, Paris.
Friday, April 11, 2025, 12:15 p.m. to 1:30 p.m.
What to Do With All the Data? Substantiating Tax Positions in the Face of Tidal Waves of Data
Kostelanetz attorney Melissa Wiley will speak on a panel that delves into how Big Data has changed tax investigations and how to best advocate for your client in light of the large amounts of data available to taxing authorities worldwide.
Other participants include co-chair Thomas Linder of MME Legal, Zurich; co-chair Travis Thompson of Boutin Jones, San Francisco, CA; Ramona Azzopardi of WH Partners, Ta’ Xbiex; Alexandra Courela of Abreu Advogados, Lisbon; Stefan Richter of YPOG, Hamburg; and Wouter Vosse of Hamelink & Van den Tooren N.V., Amsterdam.
About Kostelanetz’s Speakers
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. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
Melissa comes from an actuarial background that provides her a deep understanding of data analysis, statistics, and collaboration with technical, legal, and forensic professionals. Melissa was an assistant general counsel at a Big Four accounting firm and has litigation experience in the U.S. Tax Court, Court of Federal Claims, and various federal district courts. She focuses her practice on federal and state tax controversies international information reporting compliance, and representing clients facing government investigation.
Heather focuses her practice on multinational businesses and high net-worth individuals in need of international tax planning. She counsels both U.S.- and foreign-owned businesses and individuals regarding the U.S. tax consequences of cross-border investments, cryptocurrency issues, mergers and acquisitions, joint ventures and restructurings. Heather also regularly advises clients on special issues arising in international tax controversies. Heather is also the co-founder of the ABA’s Women in Tax Forum.

Domestic & Foreign Partnership Tax Planning Seminars at PLI Institute
2025-04-22 - 2025-04-24
Partner Megan Brackney and counsel Andy Weiner will present two seminars at the Practicing Law Institute’s (PLI) Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2025 program in Chicago, IL on April 22-24, 2025.
PLI’s 3-day program is dedicated to the intricacies of Subchapter K and partnership taxation. The third day is expressly designated for highly complex partnership and joint venture issues, tax planning, audit defense, and industry-specific topics in partnership taxation.
You can learn more about the PLI partnership tax planning program and register here.
Kostelanetz attorneys will share their experience and knowledge in the following seminars:
BBA Partnership Audit Rules in the Transactional Context
April 24, 2025, 8:30 AM CDT
Megan Brackney will participate in this session which focuses on the transactional contexts of BBA (Bipartisan Budget Act of 2015) audit rules when a partnership liquidates and whether the cease-to-exist rules or failure-to-pay rules apply, and how to advise clients on the risks and benefits of BBA indemnities.
Other panelists include Jennifer M. Black and Kate Kraus.
Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Partnership Tax Advisor Should Know
April 24, 2025, 4:15 PM CDT
Andy Weiner will participate in this panel which focuses on the ethical standards of advising clients in partnership and other pass-through entity transactions as provided in the Internal Revenue Code, Circular 230, AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct. The panel will highlight ethical pitfalls as well as privileges and rights of the taxpayer.
Other panelists include Bradley M. Seltzer.
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan is the current Chair-Elect of the American Bar Association Section of Taxation, and a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and tax controversy.
Andy focuses on tax controversies, both civil and criminal, at the agency level and in litigation. He has argued more than 50 tax cases in the U.S. courts of appeals. Andy is a fellow of the American College of Tax Counsel, a contributor to Forbes on tax controversy and tax policy issues, and a frequent writer and speaker on tax issues.

Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know
2025-04-24
Andy Weiner will present on a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” at the Practicing Law Institute’s (PLI) three-day Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances conference in Chicago on April 24, 2025.
Andy’s panel, co-run with Bradley Seltzer of Holland & Knight, will focus on practice standards and ethical standards that apply to practitioners during the partnership tax planning process. Attendees will learn the key provisions related to advising clients on partnership and pass-through transactions under Circular 230, AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct and how to navigate the ethical pitfalls that may arise when providing tax opinions and recommending return positions.
PLI’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances conference is a comprehensive three-day program designed for tax law and complex commercial litigation professionals of all skill levels. The first two days of the event are dedicated to the framework and intricacies of Subchapter K, with the third day devoted to specialized topics like ethics rules, specific industries, and international tax compliance tailored to practitioners focusing on partnership taxation. The conference will take place April 22-24, 2025, at 300 East Randolph Street, Suite 5000, near Millennium Park. Virtual attendance options are also available. You can learn more about the conference and register here.
About Andy
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has argued approximately 50 tax cases in the U.S. courts of appeals. He is a Forbes contributing columnist on tax controversy and tax policy and a frequent writer and speaker on tax issues. He is also a fellow of the American College of Tax Counsel.

Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2025
2025-05-08
Bryan Skarlatos will present a program on May 8, 2025, for the Practicing Law Institute’s (PLI) Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2025 program. PLI’s three-day program, May 6-8, 2025, promises to offer a comprehensive study of partnership taxation, including the latest legislative, regulatory, and judicial developments, advanced and industry-specific issues, and planning techniques, along with updates on the latest guidance and regulations from partnership tax experts and representatives from the government.
The event will be held in person at the Anita C. Shapiro Conference Center, 1177 Avenue of the Americas, New York, New York, but will also be available online.
“Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Partnership Tax Advisor Should Know”
May 8, 2025, 4:15 p.m. EDT
Bryan’s panel will focus on the various judicial doctrines, privilege issues, and penalty and ethical standards that apply to practitioners during the partnership tax planning process.
Bryan’s co-presenter will be Jennifer Breen of Morgan Lewis.
After completing the session, participants will be able to:

Identify the penalty and ethical standards related to advising clients on transactions involving partnerships and other passthrough entities, including the penalty standards in the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions
Anticipate how the attorney-client privilege, work product doctrine, and even the 5th Amendment privilege could affect any potential audit of the taxpayer

Learn more about the three-day program and register here.

ABA Tax Section May 2025 Meeting
2025-05-08 - 2025-05-10
Kostelanetz attorneys Michael Waalkes, Abigail Burke, and Jay R. Nanavati will be presenting on various tax topics at the American Bar Association Tax Section’s May Meeting May 8-10, 2025. Topics Kostelanetz attorneys will cover include the U.S. Supreme Court’s decision to consider Zuch v. Commissioner, IRS guidance on the ability of fraud victims to take theft loss deductions, and subcommittee updates on civil and criminal tax penalties.
Zuch v. Commissioner: Supreme Court to Tackle Offsets and Mootness Issues
May 9, 2025, 8:00 a.m.
Michael Waalkes will participate in a panel addressing the U.S. Supreme Court’s recent grant of a writ of certiorari in Zuch v. Commissioner. The power to offset is the IRS’s most widely used enforcement tool to collect on an unpaid liability. Despite its frequent use, the offset power raises significant legal issues that have often escaped attention. With the Supreme Court’s acceptance of cert in Zuch v. Commissioner, some of these issues are now in the spotlight. In addition, Zuch raises fundamental questions about the roles of the IRS and the Tax Court in collection due process (CDP) proceedings. This panel will discuss some of these questions, including whether the IRS can unilaterally deprive the Tax Court of jurisdiction in a CDP case and whether the Tax Court should be able to exercise overpayment jurisdiction in cases raised under Section 6330(c)(2)(B).
Other participants include moderator Leslie Book of the Villanova University Charles Widger School of Law, Caleb Smith of the Minnesota Law School, Audrey Patten of the Low Income Taxpayer Clinic of Harvard Law School, and Deanne Morton of Andersen Tax.
Imposters, Unknowns, and Accession to Wealth: Revisiting the Tax Consequences of Scams in 2025
May 9, 2025, 9:00 a.m.
Abigail Burke will participate on a panel that will tackle the most recent IRS guidance regarding the ability for scam victims to take a theft loss under IRC section 165(c)(2) exception to casualty loss limitations under the TCJA. Topics will include a discussion regarding the recent IRS guidance as to what constitutes a profit motive and the timing considerations for when a loss becomes fixed and determinable vs simply an unknown. Additionally, this panel will debate the possibility for scam victims to claim non-recognition of income for amounts transferred to scammers pursuant to the criteria cited in Balint v. Commissioner T.C. Memo. 2023-118.
Additional participants include moderator James Creech of Baker Tilly and panelist Benjamin Satterthwaite of Caplin & Drysdale.
High Tea and High Court, Women in Tax Forum
May 9, 2025, 8:30 a.m.
Caroline Ciraolo will participate in a panel featuring trailblazing women who rolled up their sleeves, worked groundbreaking cases, and advocated their way into the high courts. Join the Women in Tax Forum for an in-person tea moderated by Chardéa Murray-Horn and Grace Fraser, and additional panelists Sheri Dillon of Morgan Lewis & Bockius LLP, Miriam Fisher of Latham & Watkins, LLP, Lee Meyercord of Holland & Knight, LLP, and Nina Olson of the Center for Taxpayer Rights.
Civil & Criminal Tax Penalties
May 10, 2025, 8:30 a.m.
Jay Nanavati will participate in the subcommittee updates of the ABA Tax Section’s subcommittee updates and present on Important Developments in Criminal Litigation.
Additional participants include Bob Lyons, the Chief of the Criminal Appeals & Tax Enforcement Policy Section of the Justice Department’s Tax Division, and Siana Danch of Ballard Spahr LLP.
High Tea and High Court, Women in Tax Forum
May 10, 2025, 9:30 a.m.
Caroline Ciraolo will participate in a panel to discuss tax enforcement in an ever-changing landscape of IRS personnel and government staffing priorities. Expert panelists will review IRS enforcement priorities and advocacy strategies in light of recent modifications at the IRS.
Other participants include moderator Miriam Fisher, Latham & Watkins LLP, and panelists Larry Campagna, Chamberlain, Hrdlicka, White, Williams & Aughtry, P.C.; and Chad Nardiello, Nardiello Turanchik Tompkins LLP
For more information on the May Tax Meeting and to register, click here.

PS+ Leaders Conference Panel on Risk Management: Going to Offshore
2025-05-19
Kostelanetz partner Caroline Rule was featured on a panel on risk management, “Going to Offshore,” at the 2025 PS+ Leaders Conference, Confidence in Motion, hosted by Aprio in San Antonio, Texas, on May 19, 2025. The PS+ (now Aprio CPA Alliances) Leaders Conference brings together accounting services leaders from across the United States and Canada annually, with more than 50 large and mid-sized firms represented at this year’s conference.
Caroline was joined by fellow panelists Jamie Brandon, chief operating officer of Gallagher Flynn & Company LLP, Michele Graham, partner at Harding Shymanski & Company P.S.C., and Anshul Agrawal, founder of June15 Consulting. The panelists of “Going to Offshore” discussed outsourcing tax preparation overseas, including data protection safeguards for sharing client information and best practices for managing offshore operations. Caroline discussed how Section 7216, its complex associated Treasury Regulations, Rev. Proc. 2013-14, and the FTC Safeguards Rule all govern tax return preparers’ disclosure of taxpayer information outside the United States.
The panelists discussed several key international taxation and data privacy regulations as well.
About Caroline
Caroline is a tenacious advocate for her clients, many of whom face white collar criminal investigations and prosecutions, or civil tax audits and investigations. Caroline has extensive experience in advising accounting firms on how to comply with confidentiality rules protecting disclosure of client tax return information, under Section 7216 of the Internal Revenue Code and associated Treasury Regulations and IRS authorities, the Gramm Leach Bliley Act and FTC Safeguards Rule, and the AICPA Rules of Conduct, particularly as firms begin to outsource return preparation offshore.

Misunderstandings About Risk Distribution: Western Region Captive Insurance Conference
2025-05-19 - 2025-05-21
Kostelanetz partner Melissa Wiley will speak at the Western Region Captive Insurance Conference, which will be held from May 19 to 21, 2025, in Salt Lake City, UT.
Melissa’s session — on Wednesday, May 21, from 10:20 to 11:00 a.m. — is titled “Misunderstandings about Risk Distribution.” In this session, Melissa and her co-panelist will discuss the current approach taken by the Tax Court examining risk distribution in captive insurance cases and the actuarial underpinnings of the concept of risk distribution. Melissa will be joined by Hale Stewart of Higginbotham Insurance.
The Western Region Captive Insurance Conference will be held at the Salt Lake Marriott Downtown at City Creek on 75 S West Temple Street. Only in-person attendance is offered. CPE credit is given for most sessions, including Melissa’s session. You can learn more about the conference and related golf tournament here.
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.

Show Me the Money: A Primer on Restitution and Forfeiture Issues
2025-05-19 14:00 - 15:00 (America/New_York)
Kostelanetz partner Caroline Ciraolo will join colleagues in the Women’s White Collar Defense Association (WWCDA) to present, “Show Me the Money: A Primer on Restitution and Forfeiture Issues,” on Monday, May 19, 2025, from 2 p.m. to 3 p.m. ET.
The webinar will discuss forfeiture and restitution in white collar defense cases, including the unique issues presented in criminal tax prosecutions. Members of WWCDA can learn more about this webinar here.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s 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.

Cambridge Forum on International Tax & Disputes
2025-05-21 - 2025-05-23
Kostelanetz partner Caroline Ciraolo and her colleague Susanne Schreiber of Switzerland-based Bär & Karrer Ltd will co-chair the 2025 Cambridge Forum on International Tax & Disputes in Cascais, Portugal, from May 21 to 23, 2025.
The Forum invites leading lawyers from renowned regional, national, and multinational firms to convene and discuss the latest developments in international tax compliance and disputes. Issues to be addressed during the 2025 Forum include global updates in tax enforcement, privacy and data security, GAAR and beneficial ownership, special entities, and resolution mechanisms for uncertainties and disputes. Using candid, seminar-style discussion, the group shares experiences and engages in meaningful dialogue on the most pressing issues they face.
You can learn more about the Cambridge Forum on International Tax & Disputes here.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s 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.

10th International Conference on Taxpayer Rights
2025-06-04 - 2025-06-06
Kostelanetz partner Caroline Ciraolo will speak on a panel at the 10th International Conference on Taxpayer Rights sponsored by the Center for Taxpayer Rights. The conference will be held in Washington, D.C., at George Washington University’s Textile Museum from June 4 to 6, 2025. Kostelanetz LLP is a proud sponsor of the event.
Caroline’s panel, “Participation, Transparency, Trust and the Rule of Law,” will cover several aspects of international tax compliance and the interplay of information exchanges between countries and taxpayers’ rights to privacy.
Modern international tax administration is founded on the exchange of information between countries. This approach can ensure that taxpayers are not evading their responsibilities in their home countries, but it also raises the risk that taxpayers’ right to privacy can be compromised through improper use of the information exchanged, with little recourse to courts that appear unwilling to examine the good faith of international tax administrators in international summons requests. Establishing a global regime of information exchange also means that developing countries must have representation and a voice in global decision-making. Further, most countries have embedded in their constitutions or laws a recognition of citizens’ right to access information about their government’s actions and the right to participate in rule-making that affects them. This panel will discuss the interaction between these goals and how to find a path forward that recognizes and respects the interests in play.
Cara Griffith of Tax Analysts will moderate the panel, where Caroline will be joined by Leslie Book of Villanova University School of Law, Filippo Nosada of Mishcon de Reya, and Katerina Perrou, Legal Counsel to the Governor of the IAPR, Greece.
The International Conference on Taxpayer Rights was launched in 2015 by Nina E. Olson, former IRS National Taxpayer Advocate and current Executive Director of the Center for Taxpayer Rights.
The conference also offers a free workshop on June 4 on “The Role of Tax Clinics and Taxpayer Advocates/Ombuds in Promoting Trust and Protecting the Rule of Law,” and a networking dinner on June 5. Virtual attendance options are also available.
You can learn more about the conference and register here.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s 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.

Examining the Change of Administration’s Influence on SEC Regulations and Securities Enforcement
2025-06-11 - 2025-06-13
Kostelanetz partner Victor Suthammanont will speak at the American Academy of Attorney-CPAs (AAA-CPA) 2025 Annual Meeting and educational conference, which will be held from June 11 to 14, 2025, in Washington, D.C.
Victor’s session — on Friday, June 13, from 1:15 to 2:15 p.m. — is titled “Examining the Change of Administration’s Influence on SEC Regulations and Securities Enforcement.” In this session, Victor will discuss the numerous changes made to the U.S. Securities and Exchange Commission by the Trump administration and the potential challenges practitioners may expect in the near future.
The AAA-CPA conference will be held at The Westin Georgetown on 2350 M Street, NW, Washington, D.C. Only in-person attendance is offered. CLE credit is given for each session attended. You can learn more about the conference and register here.
About Victor
Victor Suthammanont served for a decade as an enforcement attorney at the U.S. Securities and Exchange Commission, including as a Senior Trial Counsel and as the Enforcement Counsel to Chair Gary Gensler. Prior to his extensive experience in the SEC’s Division of Enforcement, Victor represented and advised clients in private practice in complex commercial disputes and litigations, as well as in internal and governmental investigations.

New York City Bar - Tax Law Conference 2025
2025-06-12
Kostelanetz partner Michael Sardar will speak at New York City Bar’s Tax Law Conference 2025 on Thursday, June 12, 2025.
Michael will deliver a presentation titled “Circular 230 Discussion: What should tax professionals do when they discover an error on a client’s prior tax return” from 4:00 pm to 4:50 pm on June 12.
The New York City Bar Tax Law Conference 2025 offers a comprehensive day of insights and networking for lawyers, tax professionals and accountants, including a networking luncheon. Learn from experts in the industry as they present in depth sessions covering important trends and emerging legal developments in:

Estate Planning
Nonprofits, Family Offices and Foundations Tax
Personal and Business Entities
International
White Collar Crimes

To learn more about the conference and to register, click here.
About Michael
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.

Webinar: Tax Exemption and the New Scrutiny of Nonprofits
2025-06-12 12:00 - 13:00 (America/New_York)
Partner Megan L. Brackney will be part of a webinar panel hosted by Pace University’s Elisabeth Haub School of Law on Thursday, June 12, 2025, from 12 p.m. to 1 p.m. Eastern. This webinar is sponsored by the American Tax Policy Institute, and Kostelanetz LLP is a proud co-sponsor.
The webinar will cover the evolving regulatory challenges that nonprofit and tax-exempt organizations are facing, given recent changes in administrative priorities. The program will examine concerns about heightened scrutiny of organizational language, mission statements, and program activities, among other things. Panelists will offer practical guidance for nonprofit leaders and advisors on navigating regulatory uncertainty while maintaining organizational integrity and mission focus. The discussion will place current developments in historical context and provide forward-looking strategies for nonprofit governance, compliance, and risk management in a complex regulatory environment.
Megan will be joined by Bridget J. Crawford of the Elisabeth Haub School of Law at Pace University and American Tax Policy Institute; Ellen P. Aprill of the Lowell Milken Center for Philanthropy and Nonprofits at UCLA School of Law, LMU Loyola Law School, and American Tax Policy Institute; Brandon DeBot of the Tax Law Center, NYU Law; and Phil Hackney, University of Pittsburgh School of Law.
You can learn more about the webinar and register here.
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.
