Bryan C. Skarlatos Moderates A Panel Entitled "Non-Filers" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 13:30 - 14:30 (America/New_York)
On June 4, 2021, Bryan C. Skarlatos moderates a panel entitled “Non-Filers” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: In May of 2020 a report was issued by the Treasury Inspector General for Tax Administration criticizing the IRS for knowing about more than 10 million non-filers, many of whom are high-income earners, and not pursuing them. The IRS assured us that, no, they do have a program and are pursuing them. So, a year later where is the IRS in regards to its non-filer program? Join our experts and hear what the IRS is doing to bring non-filers into the system and when does a taxpayer’s failure to comply constitute criminal behavior.
Moderator: Bryan C. Skarlatos, Esq. Kostelanetz & Fink, LLP, New York, NY
Panelists:
Sara Neill, Esq., Capes Sokol, St. Louis, MO
Hank Kea, Director, Field Collection Operations, Small Business/Self-Employed Division, Internal Revenue Service, Washington, D.C.
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Caroline D. Ciraolo Participates In A Panel Entitled "The Criminal Investigation Part 1: Inside The Defense Room" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 14:45 - 16:00
On June 4, 2021, Caroline D. Ciraolo participates in a panel entitled “The Criminal Investigation Part 1: Inside the Defense Room” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: Never been inside a conference room with defense counsel sorting out the taxpayer’s defense to potential criminal tax charges? This program will allow the attendees to walk into that conference room and listen in while the taxpayer and his defense counsel prepare for the conference with the government, and the forensic accountant reports what she has found. (Scripted Meeting.)
Taxpayer: Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Defense Counsel 1: Caroline D. Ciraolo, Esq., Kostelanetz & Fink LLP, Washington, DC
Defense Counsel 2: Frank Agostino, Esq., Agostino & Associates, PC, Hackensack, NJ
Forensic Accountant: Sareena Sawhney, MBA, CFE, Withum, Smith & Brown, PC, New York, NY
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Caroline D. Ciraolo Participates In A Panel Entitled "The Criminal Investigation Part 2: Meeting With The Government" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 16:00 - 17:00
On June 4, 2021, Caroline D. Ciraolo participates in a panel entitled “The Criminal Investigation Part 2: Meeting with the Government” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: After hearing the government’s case, the taxpayer decides to accept responsibility and plead guilty. A plea agreement is negotiated and signed, the taxpayer appears before the court, enters his plea, and is now preparing for sentencing. This last session welcomes you into the courtroom to observe the sentencing, followed by a debrief meeting with defense counsel and the defendant to discuss the sentence imposed and what lays ahead.
Moderator: Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT
Panelists:
Frank Agostino, Esq. Agostino & Associates, Hackensack, NJ
Caroline D. Ciraolo, Esq., Kostelanetz & Fink, LLP, Washington, DC
Anastasia King, Asst. United States Attorney, New Haven, CT
Jeffrey Miller, Supervisory Special Agent, IRS Criminal Investigation, White Plains, NY
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Caroline D. Ciraolo Participates In A Panel Entitled "The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home" At The Bahamas Financial Services Board
2021-06-08
On June 8, 2021, Caroline D. Ciraolo participates in a panel entitled “The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home” at the Bahamas Financial Services Board.
The Bahamas Financial Services Board (BFSB) represents an innovative commitment by the financial services industry and the Government of The Bahamas to promote a greater awareness of The Bahamas’ strengths as an international financial center.
Click here to visit BFSB’s website.

Jay Nanavati Participates In A Panel Entitled "The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home" At The Bahamas Financial Services Board
2021-06-08
On June 8, 2021, Jay Nanavati participates in a panel entitled “The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home” at the Bahamas Financial Services Board.
The Bahamas Financial Services Board (BFSB) represents an innovative commitment by the financial services industry and the Government of The Bahamas to promote a greater awareness of The Bahamas’ strengths as an international financial center.
Click here to visit BFSB’s website.

Caroline Rule Participates In A Panel Entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” For The National Association Of Women Lawyers
2021-06-17 15:00 - 16:00
On June 17, 2021, Caroline Rule participates in a panel entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” for the National Association of Women Lawyers.
This program will address the scope and applicability of the common interest doctrine to communications among parties aligned in corporate transactions and litigation matters, and will discuss steps counsel can take to help protect such communications from later disclosure under the common interest doctrine.
Panelists:
Caroline Rule, Kostelanetz & Fink, LLP
Victoria Buter, Kutak Rock LLP
Jacqueline Rogers, Potter Anderson & Corroon LLP
Lisa Sarver, Kutak Rock LLP
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Caroline D. Ciraolo Co-Chairs A Panel Entitled "Criminal Tax Enforcement Across The Americas" At The Virtual 13th Annual U.S. And Latin American Tax Practice Trends Conference
2021-06-24 11:30 - 12:45
On June 24, 2021, Caroline D. Ciraolo co-chairs a panel entitled “Criminal Tax Enforcement Across the Americas” at the Virtual 13th Annual U.S. and Latin America Tax Practice Trends Conference for the American Bar Association Section of Taxation, the International Bar Association Taxes Committee, and the International Fiscal Association-USA Branch.
Governments around the world are actively investigating and prosecuting tax crimes. These investigations often focus on aggressive, complex tax planning strategies by companies and their officers, and sophisticated financial transactions of high wealth individuals and their professional advisors engaged in broad, cross-border conduct. To identify and effectively prosecute these cases, governments are deploying all available resources and investigative tools. This panel will address the state of criminal tax investigations and prosecutions across the Americas. The panelists will delve into the current enforcement priorities and discuss some of the “ripped from the headlines” cases in their respective jurisdictions.
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Don Fort Participates In A Panel Entitled "Global Corruption Challenges: The Need For Transparency, Training, And Effective Laws" For AML RightSource
2021-06-24 13:00 - 14:00
On June 24, 2021, Don Fort participates in a panel entitled “Global Corruption Challenges: The need for transparency, training, and effective laws” for AML RightSource.
This installment of the AML Voices series consists of a panel of experts discussing the challenges of global corruption from various perspectives, including regulatory, enforcement, advocacy, and global impact. Panelists include Tom Cardamone, Bob Pasley, Don Fort, and Pascale Dubois.
In this webinar, audience members learn about:

How international emergencies overwhelm compliance programs; how to close the gap on enforcement efforts against corrupt officials
Importance of existing and pending laws in impacting the efforts to reign in global corruption and fraud
The current administration’s focus on the adverse impact of global corruption; proposals in Congress on global corruption
Know Your Employee, FCPA, and Britain’s Anti-Corruption Act; Case Study from the Siemen’s Case

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Megan L. Brackney Participates In A Panel Entitled "Tips For Handling Audits Of Pass-Through Entities Under The Centralized Partnership Audit Regime" At The NYU Tax Controversy Forum
2021-06-24 17:00 - 18:00
On June 24, 2021, Megan L. Brackney participates in a panel entitled “Tips for Handling Audits of Pass-Through Entities Under the Centralized Partnership Audit Regime” at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business.
The use of partnerships and other flow-through structures has continued to expand and now accounts for over 50% of all net business income in the United States. With a growing consensus around increased funding for the IRS, a significant uptick in partnership examination activity is expected, focusing particularly on complex ownership arrangements, cross-boarder activities and structured transactions. For most, these examinations will be conducted under the new centralized partnership audit regime. For partnerships who elect out of the centralized audit regime, the IRS will have to audit, assess and collect from individual partners. This panel discusses practical topics such as how the IRS links partnership and partner cases in its systems, IRS’ challenges in obtaining statute extensions from all partners, the potential for inconsistent results, and strategies for representing partnerships that have opted out of the centralized audit regime.
Moderator:
Mike Desmond, Gibson Dunn & Crutcher, LLP, Los Angeles, CA
Panelists:
Megan Brackney, Kostelanetz & Fink, LLP, New York, NY
Rochelle Hodes, Crowe, LLP, Washington, DC
Holly Paz, Deputy Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC
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Bryan C. Skarlatos Moderates A Panel Entitled "New Leadership In The Taxpayer Advocate's Office: One Year Later" At The NYU Tax Controversy Forum
2021-06-25 13:00 - 13:30
On June 25, 2021, Bryan C. Skarlatos moderates a panel entitled “New Leadership in the Taxpayer Advocate’s Office: One Year Later” at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business.
On March 30, 2020, just as the Pandemic hit, Erin Collins took over as the new National Taxpayer Advocate to lead the Taxpayer Advocate Service. Before becoming the Taxpayer Advocate, Ms. Collins represented taxpayers before the IRS in private practice and she brings that perspective to TAS. This panel covers the types of matters TAS handles, tips on how to open cases, challenges presented by the Pandemic and will provide insight into the role that TAS plays in IRS compliance and enforcement.
Moderator:
Bryan Skarlatos, Kostelanetz & Fink, LLP, New York, NY
Panelist:
Erin M. Collins, National Taxpayer Advocate, Internal Revenue Service, Washington, DC
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Don Fort Moderates A Panel Entitled "What's New In IRS Criminal Investigations" At The NYU Tax Controversy Forum
2021-06-25 13:30 - 14:00
On June 25, 2021, Don Fort moderates a panel entitled “What’s New in IRS Criminal Investigations” at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business.
Schemes to defraud the IRS are becoming more complex every day and IRS Criminal Investigation is responsible for investigating and prosecuting those intent on paying less than their share of tax. CI special agents are trained to use specialized technology to wade through computerized financial records and recover data to help prosecute tax evasion. The globalization of business transactions, the pandemic, and a limited budget have made CI’s job even more challenging. This panel features the former and current Chiefs of IRS CI, discussing how the IRS will meet these challenges and continue to enforce the tax law.
Moderator:
Don Fort, Kostelanetz & Fink, LLP, Washington, DC
Panelist:
Jim Lee, Chief, Criminal Investigation, Internal Revenue Service, Washington DC
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Megan L. Brackney Participates In A Panel Entitled "Cryptocurrency: Navigating Minefields in the Virtual Currency World" For The IFA USA
2021-07-28 13:30 - 14:30
On July 28, 2021, Megan L. Brackney participates in a panel entitled “Cryptocurrency: Navigating Minefields in the Virtual Currency World” for the USA Branch of the International Fiscal Association. The IFA USA is hosting its New York Regional Conference virtually on Wednesday, July 28 and Thursday, July 29. The purpose of this panel is to help audience members understand ethical considerations related to cryptocurrency, analyze ethical issues of case studies in the cryptocurrency space, and identify ethical rules that apply to cryptocurrency transactions.
Moderator:
Pam Fuller, International Tax Counsel at Tully Rinckey and Zahn Law Group
Panelists:
Megan L. Brackney, Esq., Kostelanetz & Fink, LLP
Rebecca Lee, Principal, PwC
Lawrence Zlatkin, Vice President Tax, Coinbase
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Caroline D. Ciraolo Participates In A Panel Entitled “Voluntary Disclosure Practice 2021 and Beyond” For The Texas Bar’s 39th Annual Tax Law: Practicing Tax Law In Uncertain Times Program
2021-08-20 15:00 - 16:00
On August 20, 2021, Caroline D. Ciraolo participates in a panel entitled “Voluntary Disclosure Practice 2021 and Beyond” for the Texas Bar’s 39th annual Tax Law: Practicing Tax Law in Uncertain Times program.
Description: In light of the current and anticipated increase in civil and criminal tax enforcement, Caroline Ciraolo and Daniel Price review the IRS Relief Procedures for Former U.S. Citizens and the current Voluntary Disclosure Practice, including extensive updates to the Internal Revenue Manual provisions that address eligibility, the lookback period and penalty framework, cooperation requirements, and revocation procedures.
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Caroline D. Ciraolo Moderates A Panel Entitled “Compliance Initiatives and Voluntary Disclosure Practice – Perspectives and Updates from Puerto Rico's Hacienda and the IRS” For The ABA Section Of Taxation
2021-09-09 13:00 - 15:10
On September 9, 2021, Caroline D. Ciraolo moderates a panel entitled “Compliance Initiatives and Voluntary Disclosure Practice – Perspectives and Updates from Puerto Rico’s Hacienda and the IRS” for the American Bar Association Section of Taxation.
Description: In light of the current and anticipated increase in civil and criminal tax enforcement, and the new IRS campaign to address taxpayers who have claimed benefits through Puerto Rican residency programs, this panel reviews the history of Puerto Rico Acts 20 and 22, the use and abuse of these residency programs, potential civil penalties, current enforcement efforts, and potential paths to compliance, including a review of the current Voluntary Disclosure Practice. Panelists include key personnel within the Internal Revenue Service and Departamento de Hacienda de Puerto Rico.
Moderator:
Caroline Ciraolo, Kostelanetz & Fink, LLP
Speakers:
Daniel N. Price, IRS Office of Chief Counsel
Ladd C. Brown, IRS Office of Chief Counsel
Roxanna Santiago Ortiz, Hacienda
Angel Pantoja Rodríguez, Hacienda
Mildred Valentin Alvarez, Hacienda
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Bryan C. Skarlatos Participates In A Program Entitled "The Anti-Money Laundering Act of 2020: A Review of Selected Provisions" For Lawline
2021-09-10 14:30 - 16:00
On September 10, 2021, Bryan C. Skarlatos participants in a program entitled “The Anti-Money Laundering Act of 2020: A Review of Selected Provisions” for Lawline.
On January 1, 2020, over a Presidential veto, Congress passed the Defense Appropriations Act. Included in the Act, at Subpart F, is the Anti-Money Laundering (AML) Act of 2020. The Act is the first set of amendments to the Bank Secrecy Act and related statutes in over 50 years. The Act contains major changes, including a Corporate Transparency Act, treatment of cryptocurrency, regulation of sales in antiquities, and upcoming changes to Know Your Customer (KYC), suspicious activity reporting, and related requirements for regulated entities. The program, taught by tax attorneys Ian Comisky and Bryan Skarlatos, will discuss the highlights of the changes currently affecting practitioners this year and in the years to come.
Panelists:
Bryan C. Skarlatos, Kostelanetz & Fink, New York, NY
Ian M. Comisky, Fox Rothchild, Philadelphia, PA
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Bryan C. Skarlatos Participates In A Program Entitled "Attorney-Client Privilege and Work Product Doctrine in an Era of Increased Tax Enforcement"
2021-09-15 12:00 - 13:00
On September 15, 2021, Bryan C. Skarlatos participates in a program entitled “Attorney-Client Privilege and Work Product Doctrine in an Era of Increased Tax Enforcement.”
Panelists:
Bryan C. Skarlatos, Kostelanetz & Fink, New York, NY
Ian M. Comisky, Fox Rothchild, Philadelphia, PA

Caroline D. Ciraolo Participates In A Panel Entitled “Promoting Diversity, Equity, and Inclusion in Tax: Ideas and Resources for Mentoring Diverse Students and Leading Discussions of DEI in Tax” For The ABA Section Of Taxation's Virtual Fall Meeting
2021-09-22 12:30 - 14:00
On September 22, 2021, Caroline D. Ciraolo participates in a panel entitled “Promoting Diversity, Equity, and Inclusion in Tax: Ideas and Resources for Mentoring Diverse Students and Leading Discussions of DEI in Tax” for the American Bar Association Section of Taxation’s Virtual Fall Meeting. The meeting is a five-day event led by the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.
Description: This panel documents the need for greater diversity in the field of tax law − in practice and in Academia – and shares ideas to promote this goal, with a focus on law students and recent law school graduates. The panelists (1) provide information about existing programs to promote DEI in the tax profession, (2) discuss ways to build the tax profession pipeline, to recruit and retain diverse tax attorneys, and to provide strong platforms for professional success, and (3) solicit audience participation and ideas for new initiatives.
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Caroline D. Ciraolo Participates In A Panel Entitled “John Doe Summonses: The Tool to Close the Crypto Compliance Gap and Implications for Privilege” For The ABA Section Of Taxation's Virtual Fall Meeting
2021-09-22 14:30 - 16:00
On September 22, 2021, Caroline D. Ciraolo participates in a panel entitled “John Doe Summonses: The Tool to Close the Crypto Compliance Gap and Implications for Privilege” for the American Bar Association Section of Taxation’s Virtual Fall Meeting. The meeting is a five-day event led by the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.
Description: A John Doe Summons allows the IRS, with court approval, to obtain information from a third-party about a class of taxpayers. The IRS’s use of these summonses to identify account holders of UBS made headlines in 2008. Since then, the IRS has expanded the use of John Doe Summonses as an available investigatory tool, including on domestic cryptocurrency exchanges. This panel will recount the historical use of John Doe Summonses by the IRS; examine areas in which the IRS is currently employing these summonses and where they can be used in the future; and discuss important privilege issues that may raise, an example of which is currently pending before the U.S. Supreme Court in Taylor Lohmeyer Law Firm v. United States (Docket 20-1596). The panel’s participants are as follows:
Moderator

Victor Jaramillo, Caplin & Drysdale, Washington D.C.

Panelists

Honorable Steven D. Grimberg, United States District Judge, Northern District of Georgia;
Lawrence Hill, Steptoe & Johnson, New York, NY;
Jeffrey Neiman, Marcus Neiman Rashbaum & Pineiro, Ft. Lauderdale, FL; and
Caroline Ciraolo, Kostelanetz & Fink, Washington, D.C.

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Caroline D. Ciraolo Participates In A Panel Entitled “Ethical Considerations for Former and Current Government Tax Attorneys” For The ABA Section Of Taxation's Virtual Fall Meeting
2021-09-24 13:10 - 14:00
On September 24, 2021, Caroline D. Ciraolo participates in a panel entitled “Ethical Considerations for Former and Current Government Tax Attorneys” for the American Bar Association Section of Taxation’s Virtual Fall Meeting. The meeting is a five-day event led by the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.
Description: This panel examines an attorney’s professional obligations relating to the “revolving door” of entering or leaving the federal government. The discussion focuses on a number of ethical issues for tax attorneys to consider including, among others, conflicts of interest, the duty of loyalty, and the duty of confidentiality. The panelists also cover the post-employment restrictions that impact attorneys looking for or switching to a new job. The panel’s participants are as follows:
Moderator

Michael Desmond, Partner, Gibson, Dunn & Crutcher LLP, Los Angeles, CA

Panelists

Caroline D. Ciraolo, Kostelanetz & Fink, LLP, Washington, DC; and
Kirsten N. Witter, Senior Level Counsel (General Legal Services), IRS Office of Chief Counsel, Washington, DC (Invited)

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Sharon L. McCarthy Participates In A Panel Entitled “Best Practices or Not? Internal Corporate Investigations” For The Federal Bar Council
2021-10-05 18:00 - 19:30
On October 5, 2021, Sharon L. McCarthy participates in a panel entitled “Best Practices or Not? Internal Corporate Investigations” for the Federal Bar Council. Internal corporate investigations typically result from discovery – by the company, the media, an external auditor, or a whistleblower – of circumstances that raise a serious concern of financial or other misconduct, which may expose the company, management, and the board to civil or criminal liability. The goal of internal investigations is to determine the validity and seriousness of the alleged conduct and what action, if any, the company should take consistent with the best interests of the future of the company and its employees/shareholders.
Description: This program is intended to sensitize practitioners involved in internal investigations to complex, thorny issues that frequently arise, including those relating to: attorney-client privilege; employee interviews and representation concerns; whether to cooperate with government agencies or risk enforcement action and/or criminal prosecution; cross-border issues such as data privacy laws, cultural and language differences, and the specter of both foreign and domestic investigations and litigation. The distinguished panel will share their experiences from multiple perspectives. The panel’s participants are as follows:
Moderator

John J. Kenney, Esq., Hoguet Newman Regal & Kenney, LLP

Panelists

William E. Craco, Esq., Johnson & Johnson;
Laura Grossfield Birger, Esq., U.S. Attorney’s Office, SDNY;
Henry Klehm, III, Esq., Jones Day;
Sharon L. McCarthy, Esq., Kostelanetz & Fink, LLP; and
Hon. Jed S. Rakoff, U.S. District Judge

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Don Fort Participates In A Panel Entitled "How Technology-Enabled Transformation Will Shrink the Tax Gap and Improve Taxpayer Service" At The NAPA Symposium Series On The Transformation Of The IRS
2021-10-19 12:00 - 13:30
On October 19, 2021, K&F Director of Investigations Don Fort participates in a panel entitled “How Technology-Enabled Transformation Will Shrink the Tax Gap and Improve Taxpayer Service” for the National Association of Public Administration’s Symposium Series on the Transformation of the IRS.
This panel focuses on how the IRS can more effectively deploy advanced, but available, technologies such as machine learning to significantly reduce the tax gap by providing top-notch taxpayer service and more effectively finding taxpayers who have not fully reported the taxes that they legally owe. The panel discusses the challenges related to deploying new technologies while simultaneously modernizing the IRS’s very old core accounting systems. This panel, moderated by Dr. Fred Forman, former EVP for American Management Systems and IRS Associate Commissioner for Modernization, explores these issues.
Panelists

Richard Spires, former IRS and DHS Chief Information Officer, former President of Learning Tree International and former President of Palo Alto Systems
David Powner, NAPA Fellow and former GAO Director of IT Management Issues now with MITRE as Executive Director, Center for Data-Driven Policy
Don Fort, Director of Investigations at Kostelanetz & Fink, LLP, and the immediate past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division
Selvi Stanislaus, Executive Officer of the Franchise Tax Board (FTB)

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Megan L. Brackney Participates In A Webinar Entitled "Handling Controversy and Staying Out of Trouble (CLE Ethics)" For The UJA
2021-10-20 12:00 - 12:50
On October 20, 2021, Megan L. Brackney participates in a panel entitled “Handling Controversy and Staying Out of Trouble (CLE Ethics)” for the UJA-Federation of New York. The UJA is hosting the 52nd Annual Sidney Kess New York Estate, Tax & Financial Planning Conference on Tuesday, October 19 and Wednesday, October 20.
The webinar is described as follows:
Tax practice can be categorized into three different stages: tax planning, tax return preparation, and audit/trial representation. Each stage has its own ethical considerations. What differentiates legitimate tax planning from tax evasion? How sure do you have to be before you can tell a client it is okay to take a position on a return? Do you have to audit a client’s records, or can you rely on what the client says? After the return has been filed, how do you handle an audit when you know the client’s tax return is wrong? What do you do if the information you submitted to the IRS is not accurate? This webinar will use real-life examples and provide tips for tax professionals who want to stay out of trouble.
Learning Objectives

Recognize how ethical standards apply to everyday tax practice;
Identify sources of ethical standards and rules that you may not have known about;
Determine standards for advising taxpayers about positions on tax returns;
Differentiate when you can rely on what your client tells you and when you must ask more questions; and
Recall sticky issues that can arise during audits and other controversies.

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Caroline D. Ciraolo Moderates A Panel Entitled “FBAR Litigation Developments” For STEP USA
2021-10-21 12:00 - 13:30
On October 21, 2021, Caroline D. Ciraolo moderates a panel entitled “FBAR Litigation Developments” for STEP USA.
Description: The IRS and DOJ have been aggressive in pursuing judicial recourse to enforce and seek collection of FBAR assessments. In July of 2020, we presented a Webinar on this topic. Our upcoming Webinar will address the new and key issues and considerations in the litigation of an FBAR case, of which there have been many. The format for the presentation will be an interactive question and answer format among our panelists. There will be an opportunity for attendees to pose questions to our panelists. The panel’s participants are as follows:
Moderator

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP, Washington, DC and Baltimore, MD.

Panelists

James Dawson, Partner, Holland & Knight, West Palm Beach, FL
Jeffrey Neiman, Founding Member, Marcus Neiman Rashbaum & Pineiro LLC, Ft. Lauderdale, FL
Zhanna A. Ziering, Partner, Moore Tax Law Group, New York, NY

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Bryan C. Skarlatos Participates In A PLI Panel Entitled "Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know"
2021-10-22 13:15 - 14:15
On October 22, 2021, Bryan C. Skarlatos participates in a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know” for “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021” hosted by the Practising Law Institute (PLI).
Description: “Tax Strategies 2021” focuses on the tax issues presented by the entire spectrum of modern major corporate transactions, from single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. In their panel, Kelley C. Miller, Bryan C. Skarlatos, and Sharyn M. Fisk (Invited) discuss ethics rules related to advising clients on corporate transactions, including tax motivated transactions and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit. They also discuss the ethical rules and 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.
Panelists:

Kelley C. Miller, Partner, Reed Smith, LLP
Bryan C. Skarlatos, Partner, Kostelanetz & Fink LLP
Sharyn M. Fisk, Director, Office of Professional Responsibility, Internal Revenue Service

Robert Russell Participates In A Panel Entitled "Go Big and Go Home – Analyzing the Major Business Tax Provisions in Budget Reconciliation" For TEI’s 76th Annual Conference
2021-10-25 09:45 - 10:45
Robert Russell serves as a panelist at TEI’s 76th Annual Conference for the session called “Go Big and Go Home – Analyzing the Major Business Tax Provisions in Budget Reconciliation,” slated for 9:45 a.m.–10:45 a.m. (EDT) on Monday, October 25, 2021.
Description: Much hay has been made of potential business tax reform recently. This panel discusses practical insights to help separate the wheat from the chaff of various proposals.
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Don Fort Participates In A Panel Entitled “Cryptocurrency Update” For The FBA Section On Taxation
2021-10-26 12:00 - 13:00
*This event has been postponed until a later date. Check back for updates.
On October 26, 2021, K&F Director of Investigations Don Fort participates in a panel entitled “Cryptocurrency Update” for the Federal Bar Association’s Section on Taxation.
The panelists discuss current cases and developments in the field, technology tools and audit streams, the recent John Doe summonses, and Operation Hidden Treasure. In addition, the panelists review important changes to the Infrastructure Investment and Jobs Act, as well as IRS guidance on hard forks and like-kind exchanges.
Panelists:

Don Fort, CPA, Kostelanetz & Fink, LLP
Sarah Paul, Partner, Eversheds Sutherland
Carolyn A. Schenck, National Fraud Counsel and Assistant Division Counsel (International), SB/SE Office of Chief Counsel, Internal Revenue Service

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Caroline D. Ciraolo Moderates A Panel Entitled “IRS Undeterred: An Update on Criminal Tax Enforcement” For The American Bar Association’s 36th National Institute On White Collar Crime
2021-10-27 10:30 - 11:45
On October 27, 2021, Caroline D. Ciraolo moderates a panel entitled “IRS Undeterred: An Update on Criminal Tax Enforcement” for the American Bar Association’s 36th National Institute on White Collar Crime.
Description: While the world has been on pause, the IRS Fraud Enforcement Office and IRS Criminal Investigation have not missed a beat. Seasoned tax practitioners and IRS leadership will discuss the latest developments in IRS fraud and criminal tax enforcement, including current priorities, fraud referrals, cross border collaborations, investigative tools being used, and recent prosecutions.
Moderator:
Caroline D. Ciraolo, Kostelanetz & Fink LLP
Panelists:
Nathan J. Hochman, Browne George Ross O’Brien Annaguey & Ellis LLP
Sara G. Neill, Capes Sokol Goodman & Sarachan, P.C.
Jeffrey Neiman, Marcus Neiman Rashbaum & Pineiro LLP
R. Damon Rowe, Executive Director of Fraud Enforcement, IRS
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Caroline D. Ciraolo Facilitates A Discussion With USC Prof. Jeesoo Nam At The Tax Policy Colloquium Speaker Series, Loyola Law School
2021-11-01 15:00 - 17:00
On November 1, 2021, Caroline D. Ciraolo facilitates a discussion with Professor Jeesoo Nam (USC Tax Law) entitled “Tax Justice for Criminal Activities” for LMU Loyola Law School’s Tax Policy Colloquium. The discussion will focus on Professor Nam’s publication of the same name. The discussion’s participants are as follows:
Speaker

Jeesoo Nam, USC School of Law

Commentators

Caroline D. Ciraolo, Kostelanetz & Fink, LLP
William Bunting, Temple University

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Caroline D. Ciraolo Participates In A Panel Entitled “Tips and Traps (or Hot Topics) in Dealing with International Taxpayers and Reporting”
2021-11-04 16:45 - 18:15
On November 4, 2021, Caroline D. Ciraolo participates in a panel entitled “Tips and Traps (or Hot Topics) in Dealing with International Taxpayers and Reporting.” This panel is part of the 2021 Annual Meeting of the California Tax Bar and California Tax Policy Conference.
Description: We live in a global economy and many of your clients will have sources of income, investments, assets or activities outside the United States. With these often come complex international tax and reporting obligations, the violation of which can result in substantial civil penalties and, in cases involving willful conduct, criminal exposure. With the automatic exchange of information, increased collaboration among treaty partners, and searches driven by data analytics, it is no longer a matter of if the government will find an offshore asset, but when. This diverse panel will review the common international reporting obligations, potential penalties, applicable statutes of limitations, available defenses, and potential paths to compliance, including the latest developments in voluntary disclosures.
Speakers

Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP
Marsha Dungog, Partner, Withers Bergman
LLP
Kurt Kawafuchi, Principal, Law Offices of Kurt
Kawafuchi

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The Law Firm Antiracism Alliance Hosts A Discussion Section Entitled “Diversity in the Tax Bar” As Part Of Its Tax System Working Group Discussion Series
2021-11-05 14:00 - 15:30
Description: The LFAA Tax System Working Group, in conjunction with the American College of Tax Counsel, the American Tax Policy Institute and the Tax Section of the American Bar Association, is organizing a ten-part discussion series on diversity in the tax bar. Over the course of this series of virtual discussions, participants learn about the current state of diversity in the tax bar, opportunities for diverse tax attorneys in different practice settings, and steps that the tax bar should be taking to create sustainable diversity, equity and inclusion strategies.
The Nov. 5, 2021 discussion addresses the current state of diversity in the tax bar and how the legal profession has evolved over the past several decades.
Panelists:

Chief Judge Maurice B. Foley, United States Tax Court
Glenn Carrington, Norfolk State University School of Business
Alice Thomas, Howard University School of Law

Moderator:

Armando Gomez, Skadden, Arps, Slate, Meagher & Flom LLP

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