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.

ABA 17th Annual U.S. and Latin America Tax Practice Trends Conference
2025-06-18 - 2025-06-20
Kostelanetz attorneys Heather Fincher, Eduardo A. Cukier, and Caroline D. Ciraolo will be speaking at the ABA’s 17th Annual U.S. and Latin America Tax Practice Trends Conference held in Miami from June 18 to June 20, 2025.
This year’s conference will focus on cross-border tax practice trends for multinational corporations and other business and investment vehicles, high net worth individuals and family offices, and their international advisors, as well as provide insight into how government tax officials may view the international tax landscape in light of important international developments that impact taxpayers. Panelists will include industry leaders, senior government officials, and leading tax practitioners from the United States, Latin America, and Europe.
The ABA will seek 15 hours of CLE credit in 60-minute states and 18 hours of CLE credit in 50-minute states. Credit hours are estimated and are subject to each state’s approval and credit rounding rules.
Please join Kostelanetz attorneys for the following sessions:
Wednesday, June 18, 2025, 2:00 PM – 3:30 PM Wealth Management Session
HNW Clients and Trusts: Contemporary Trends and Challenges in Latin America
Heather Fincher will co-chair a panel on cross-border planning and complexities related to the increasing use of trusts by advisors to high-net-worth individuals throughout Latin America and the United States.
Heather will be speaking with fellow Co-Chair Hermano A. C. Notaroberto Barbosa, BMA, São Paulo and speakers José Maurício C. Abreu, Farroco Abreu Advogados, São Paulo; Alil Álvarez Alcalá, Álvarez Alcalá, SC, Mexico City; Myriam Bril, Goldman Sachs, Miami, FL; Corina Laudato, Mitrani Caballero, Buenos Aires; Javier Otegui, Guyer & Regules, Montevideo; and Jennifer J. Wioncek, Bilzin Sumberg, Miami, FL.
Wednesday, June 18, 2025, 4:00 PM – 5:30 PM Wealth Management Session
New Frontiers for Family Offices: Emerging Issues for Cross-Border Family Office Structures and Investments
Eduardo Cukier will be speaking on U.S. tax and legal complexities faced by global family offices and their opportunities in structuring cross-border operations and investments.
Eduardo will be speaking alongside Co-Chairs Seth J. Entin, Greenberg Traurig LLP, Miami; Carola Trucco Horwitz, Barros & Errázuriz, Santiago; and speakers Paulo Bento, Madrona Advogados, São Paulo; Guadalupe Diaz-Sunico, Gomez-Acebo, Barcelona, and Gabriela Pellón, Galicia, Mexico City.
Friday, June 20, 2025, 11:00 AM – 12:30 PM Concurrent Session B
Defending Multiple Fronts – The Prevalence, Perils, and Best Practices of Parallel Civil and Criminal Tax Enforcement Proceedings
Caroline Ciraolo will co-chair the panel discussion on a range of issues practitioners face when dealing with parallel civil and criminal tax enforcement proceedings.
Caroline will be joined by fellow Co-Chair Luis Suárez de Centi, Uría Menéndez, Madrid; and speakers Mario Barrera, Clark Hill, Mexico City; Juan Carlos Casellas, Mayora & Mayora, S.C., Guatemala City; Barbara R. Llanas, Gelber Schachter & Greenberg, P.A., Miami, Florida, Luis Marcelo Nuñez, Perez Alati, Grondona, Benites, & Arntsen, Buenos Aires; and Alvaro Villegas, Villegas Aldazosa & Asociados, La Paz, Bolivia.
Full conference agenda and registration info available here.
About Heather
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.
About Eduardo
Eduardo’s transactions-based domestic and international tax practice spans more than two decades advising U.S. and foreign clients across many different types of business deals in various industries. Eduardo brings an international perspective, cultural awareness, and an understanding of legal and tax systems, regulatory frameworks, and the business dynamics involved in getting deals done. That skill set has made him counsel of choice for many corporations, businesses, and entrepreneurs in the U.S., Latin America, and around the globe.
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, state, and cross-border 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.

NYU Advanced International Taxation Conference: Current Tax Penalty Issues
2025-07-18
Megan L. Brackney and Melissa Wiley will participate in an in-depth session on current tax penalty issues at the Advanced International Taxation Conference sponsored by the New York University (NYU) School of Professional Studies.
The panel will be held July 18, 2025, from 3:15 p.m. to 4:30 p.m. Conference agenda and registration information can be found here.
July 18, 2025, 3:15 p.m. – 4:30 p.m.
Current Penalty Issues
Megan and Melissa will participate in a panel that will delve into the complex filing requirements for international information returns and the often life-altering penalties imposed for noncompliance. As a result of the IRS’s increased focus on enforcement in this area in recent years, many taxpayers have challenged international information return penalties on various technical grounds and on the basis of reasonable cause. Recently, some of these challenges have been addressed by the courts. This session will discuss recent cases in the area as well as their implications going forward.
Other panelists include: Victor A. Jaramillo, Esq., Member, Caplin & Drysdale, Washington, DC; and Larry A. Sannicandro, Esq., Partner, Pillsbury Winthrop Shaw Pittman, New York, NY
NYU notes that the Advanced International Taxation Conference provides sophisticated knowledge of “hot button” issues and opportunities in international taxation such as:

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

About Megan
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. The current Chair-Elect of the American Bar Association Section of Taxation, she is also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights, helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Prior to becoming an attorney, Melissa worked in the insurance industry as an actuarial analyst.

IRS Tax Forum: Representing Businesses with No Records
2025-08-07 08:00 - 09:00 (America/Chicago)
On Aug. 7, 2025, Michael Sardar will present on a panel entitled “Representing Businesses with No Records” at the IRS Tax Forum in New Orleans, Louisiana.
Whether through natural disaster, computer failure, or poor record keeping, many businesses enter tax season without the business records their tax professional will need to prepare tax returns and defend against an IRS Audit. This panel will cover tools, tips, and strategies for tax professionals dealing with clients and taxpayers that do not have adequate and proper business records. The panel will cover reconstruction methods, the use of estimates, and the “Cohan Rule.”
Michael’s program will be held at 8:00 am CT and, then again, at 11:00 am CT on Aug. 7.
More information on the Forum, which is being held from Aug. 5-7, can be found 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.

IRS Voluntary Disclosure Practice (CLE)
2025-08-28 13:45 - 14:45 (America/Chicago)
Caroline D. Ciraolo will speak on a panel entitled “IRS Voluntary Disclosure Practice” at the TexasBarCLE’s annual Tax Law in the Digital Age conference on Aug. 28, 2025, at 1:45 p.m. Central.
Caroline and Dan Price, of the Law Offices of Daniel N. Price, will discuss the current voluntary disclosure practice, questions and concerns raised by tax professionals, recent developments, including the impact of the National Taxpayer Advocate’s efforts to assist taxpayers coming into compliance, and best practices. The presentation will be available via live webcast, and a webcast replay will be available October 9-10, 2025. CLE credit is offered for both.
More information and registration can be found 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, state, and cross-border civil tax controversies, including representation in sensitive audits, voluntary disclosures, 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.

Webinar: Tax Implications of Business Transfers and Exit Strategies
2025-09-19
Usman Mohammad will present a session titled “Tax Implications of Business Transfers and Exit Strategies” for the National Business Institute’s (NBI) “Prevent Undue Tax Burdens for Your Business Clients” full-day webinar. The webinar is on September 19, 2025, and will run from 10 a.m.-5 p.m. Eastern, with Usman’s session at 2:15 p.m. to 2:45 p.m.
NBI’s “Prevent Undue Tax Burdens for Your Business Clients” program is dedicated to small business and pass-through tax law issues, and it is designed to make tax and legal knowledge accessible for attendees who may not have prior tax law knowledge. The all-day webinar will cover a wide variety of tax topics pertinent to pass-through entities ranging from entity selection to international tax planning for closely-held businesses.
Usman’s session, “Tax Implications of Business Transfers and Exit Strategies,” will explore the taxation aspects of common small business exit strategies like selling a business and acquisition by a larger company.
You can learn more about the webinar and register here.
About Usman
Usman’s tax controversy practice includes defending clients in federal and state criminal matters involving issues such as tax shelters, payroll tax, check cashing, structuring cash deposits, filing false returns, and failing to file tax returns. He also has extensive experience with government procurement award protests, Article 78 proceedings involving procurement matters, foreign asset reporting issues, IRS responsible person and trust fund recovery penalty matters, IRS whistleblower matters, and IRS collection cases.

US SIF Webinar: Say Less, Risk More? ‘Greenhushing’ and SEC Enforcement
2025-09-19 15:00 - 16:00 (America/New_York)
Victor Suthammanont will present a webinar with other former SEC officials for the US Sustainable Investment Forum (US SIF) on the legal and regulatory hazards of under-disclosure. The webinar will take place on September 19, 2025, at 3 p.m. Eastern.
The concept of “greenhushing” is a hot-button issue in the world of corporate governance and complex commercial litigation. Akin to “greenwashing”, which is when a company presents a more environmentally conscious and sustainable image than its actual practices, greenhushing is when companies and investment firms seek to downplay their environmental, social, and governance (ESG) initiatives. For example, these entities may have removed or altered language from their websites and communications related to climate or social justice, diversity, governance, and other issues to conform to current political pressures. However, they may still communicate, in other ways, a commitment to these causes to their customers, investors, and other stakeholders.
In this webinar, Victor and the other former SEC officials will examine greenhushing from a SEC compliance and enforcement lens. What can greenhushing look like, how would it appear to the current SEC, and how can asset managers, advisers, and other parties mitigate risks while they consider new ESG-related messaging?
Victor will be joined by Mika Morse, former Policy Counsel for SEC Chair Gensler; Megan Barbero, former SEC General Counsel; and Erik Gerding, former Director of the SEC Division of Corporation Finance.
You can learn more about the webinar and register here.
About Victor
Victor served for a decade as an securities enforcement attorney in 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.

Annual Meeting of the National Association of State Bar Tax Sections
2025-09-25
Caroline Ciraolo and Andy Weiner will speak at the 46th annual meeting of the National Association of State Bar Tax Sections (NASBTS) hosted by the Washington State Taxation Section at Fox Rothschild LLP’s offices in Seattle, WA, from September 25-26, 2025.
The conference offers a wide variety of sessions in state, local, and federal taxation and tax controversy topics. Additionally, the Tax Section Boot Camp and NASBTS annual business meeting will take place at the conclusion of the day’s panels on Thursday, September 25. Continuing education credits are available.
Caroline’s panel on Thursday, September 25, from 8:15 a.m. to 9:15 a.m. Pacific is titled “Dealing with the New IRS: The State of IRS Enforcement and Its Impact on Dispute Resolution.” Panelists will discuss audit and dispute resolution trends in light of changes to the IRS in 2025. The panel will be moderated by Jaye Calhoun of Kean Miller, and Caroline will be joined by fellow panelists Parisa Griess of McDermott Will & Emery and Kevin Baker of Kean Miller.
Andy’s panel, “Federal and State Partnership Audits: Current Issues,” is on September 25 from 12 p.m. to 1 p.m. This panel will provide an overview of the centralized partnership audit regime under the Bipartisan Budget Act of 2018 (BBA), its implications for state tax systems and clients, and practice trends and strategies. The panel is moderated by Alexander Korzhen of Wagner Tax Law, and Andy will be joined by fellow panelist Kate Kraus of Covington.
You can learn more about the conference and register here.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border 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.
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.

New York State and City Procurement Law: Vendor Selection, Protests, and Article 78
2025-10-14 13:00 - 14:30 (America/New_York)
Usman Mohammad will present a webinar for BARBRI, formerly Strafford, on New York State and New York City procurement laws. The webinar will take place Tuesday, October 14, 2025, from 1 p.m. to 2:30 p.m. Eastern. Continuing education credits are available.
In the webinar, Usman will provide attendees with a thorough understanding of New York State and New York City procurement law and practices among other challenges in government contracting. Topics will include procurement methods, lobbying restrictions, vendor selection and contract registration, the protest process, and the mechanics of Article 78 proceedings.
You can learn more about the webinar and register here.
About Usman
Usman is counsel at the New York City office of Kostelanetz LLP. Usman’s practice includes New York City and State government procurement matters, civil and criminal tax controversies including tax whistleblower matters, and commercial litigation.

Practicing Law Institute: Trial by Jury 2025
2025-10-16
Sharon McCarthy will lead a panel titled “Closing Big: Delivering a Compelling Closing Argument” during the Practicing Law Institute Trial by Jury 2025 program at 4 p.m. Eastern on October 16, 2025.
This program provides a unique view into jury trials by practitioners and judges, from opening statements through closing arguments. The event is open to attorneys and allied professionals who want to learn about all aspects of handling jury trials.
Sharon will be joined by panelists Richard M. Strassberg, Partner at Goodwin Procter; the Hon. Eric R. Komitee, United States District Judge for the Eastern District of New York, and Hon. Vernon S. Broderick, United States District Judge for the Southern District of New York.
Registration and event information is available here.
About Sharon
Sharon, a Fellow of the American College of Trial Lawyers and former federal prosecutor, has extensive experience representing individuals and corporations in white-collar criminal matters, civil and criminal tax controversies, and complex commercial litigation. She is an Adjunct Professor at Fordham Law School, where she teaches Trial Advocacy.

84th Institute on Federal Taxation (NY)
2025-10-19 - 2025-10-24
Kostelanetz attorneys Megan L. Brackney and Michael Sardar will speak at the 84th Institute on Federal Taxation, hosted by the NYU School of Professional Studies. The conference will be held in New York City at The Westin at Times Square from October 19-24, 2025.
Megan’s session, “Current IRS Enforcement Efforts and the Path Ahead,” will take place on October 19th at 1:45 p.m. EST. She will be joined by Zhanna Ziering of Ziering & Esman PLLC and Phil Colasanto of Withers.
Michael’s session, “The Role of the Tax Advisor in the Tax System: Ethical and Penalty Standards for Advising Clients,” will take place on October 23rd at 5:15 p.m. EST. He will be joined by Professor V. Patrice Wylly of the NYU School of Law.
The Institute on Federal Taxation is a six-day conference that offers practitioners the opportunity to earn over 40 hours of continuing education credits in a plethora of complex tax law topics. Session topics will include current developments in tax controversy, international taxation issues, trusts and estates, executive compensation and employee benefits, practice ethics, and more.
You can learn more about the conference 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. Megan is the Chair 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 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.

41st Annual UCLA Tax Controversy Conference
2025-10-23
Kostelanetz attorneys Andrew Weiner, Bryan C. Skarlatos, and Karen Kelly will speak at the 41st Annual UCLA Tax Controversy Conference at the Beverly Hills Hotel in Los Angeles on October 23, 2025. Continuing education credit is offered, and attendance is in-person only. Kostelanetz is a proud Silver sponsor of this conference. Kostelanetz partner Caroline D. Ciraolo will also be in attendance at the conference.
Our attorneys will present the following sessions:
Thursday, Oct. 23, 2025, from 2:10 p.m. to 3:10 p.m. Pacific
“Valuation in Tax Enforcement Critical to Our Voluntary Compliance System”
Kostelanetz participant: Andy Weiner
Thursday, Oct. 23, 2025, from 3:10 p.m. to 4:10 p.m. Pacific
“Navigating IRS Resource Challenges – From the Taxpayer Advocate Service to Self-Help Options for Taxpayers and Tax Professionals”
Kostelanetz participant: Bryan Skarlatos
Thursday, Oct. 23, 2025, from 4:45 p.m. to 5:50 p.m. Pacific
“The Future Direction of Criminal Tax Enforcement”
Kostelanetz participant: Karen Kelly
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.
About Bryan
Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.
About Karen
The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. She was twice honored by the Department of Justice with the Attorney General Award for Outstanding Service. Her practice focuses on defending clients in state and federal criminal tax and white-collar investigations and prosecutions and representing clients in government investigations and enforcement actions. Karen draws on her extensive government experience to provide clients with insight and nuanced risk assessments and to provide a common-sense approach to best steps forward in complex criminal matters.

2025 Art Law Day: What’s the (Tax) Value of Art?
2025-11-07
Melissa Wiley will present a session titled “What’s the (Tax) Value of Art?” at the Appraisers’ Association of America’s (AAA) 2025 Art Law Day on November 7, 2025. The event will be held at the AAA’s New York City headquarters in Midtown Manhattan from 9:30 a.m. to 10:45 a.m. Eastern. Continuing education credits and virtual attendance options are available; however, credits are only awarded for in-person attendance.
Melissa’s session delves into the tax impact of art donations for both donors and tax-exempt organizations. Topics include how to substantiate art donations, reporting charitable contributions of art, common IRS challenges, and the risks that donors and tax-exempt organizations face. The session will be moderated by Meghan Biss of Loeb & Loeb LLP, and Melissa will be joined by fellow panelists Karin Gross of K. Tyson Law PLLC and Kristina Rasmussen of Deloitte Tax LLP.
You can learn more about Art Law Day and register 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.

University of Chicago Law School Federal Tax Conference 2025
2025-11-07
Caroline D. Ciraolo will participate as a panelist in a session titled “Is Section 6103 Providing The Protections It Promised? And Should It?” at the University of Chicago Law School’s 78th Annual Federal Tax Conference on Friday, November 7, 2025, from 10:20 a.m. to 11:50 a.m. Central at the Gleacher Center.
The panel will be moderated by John Hildy, partner, Mayer Brown LLP, and will include a presentation by Joseph Thorndike, Contributing Editor, Tax Notes and Director, Tax History Project at Tax Analysts, regarding the historical context of Section 6103. Following the presentation, the panelists, including Caroline and Michael Desmond, member, Miller & Chevalier, and former IRS Chief Counsel, will engage in a discussion regarding the scope of Section 6103, the application and limitations of the many statutory exceptions, and current scrutiny in light of agreements between the IRS and other federal agencies to support the Administration’s enforcement priorities.
You can learn more about the conference and register here.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border 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.

White Collar Support Group™ Tuesday Speaker Series: A Panel on Restitution & Forfeiture, presented by the Women’s White Collar Defense Association (WWCDA)
2025-11-11 19:00 - 20:00 (America/New_York)
Caroline D. Ciraolo will join fellow members of the Women’s White Collar Defense Association (WWCDA) to present a panel on “Restitution and Forfeiture” to the White Collar Support Group Tuesday Speakers Series. The webinar will take place November 11, 2025, from 7 p.m. to 8 p.m. Eastern.
The discussion will cover the fundamentals of restitution and forfeiture orders. Attendees will learn the differences between forfeiture and restitution, how the two concepts converge, types of assets subject to forfeiture and restitution, unique IRS issues related to restitution and corresponding civil tax liabilities, and how to limit potential exposure during white-collar criminal proceedings.
Caroline will be joined by Margaret Graham and Jillian Berman, former Department of Justice prosecutors who represented individuals and entities in government investigations and criminal and regulatory matters. They will share their insights on forfeiture and restitution in federal criminal matters and how practitioners can strategize their defenses considering recent DOJ practices.
The White Collar Support Group™ is a community of individuals, families, and groups who have been impacted by the criminal justice system. Over the past ten years, over 1,650 members have participated in over 490 weekly support group meetings from every state in the country – and Canada, the U.K., South America, Central America, Israel, Mexico, Europe, Scandinavia, and the Caribbean. The WCSG provides peer and mentoring support, white-collar job and career connections, relevant news and events, advocacy initiatives, partnerships with other nonprofits, and a wide array of other resources.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border 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.

84th Institute on Federal Taxation (San Francisco)
2025-11-16 - 2025-11-21
Kostelanetz attorneys Andrew Weiner and Bryan C. Skarlatos will speak at the 84th Institute on Federal Taxation, hosted by the NYU School of Professional Studies. The conference will be held in San Francisco at Fairmont Hotel from November. 16-21, 2025.
Andrew’s session, “Nuts and Bolts of a Partnership BBA Audit,” will take place on November 19th at 1:45 p.m. Pacific. He will be joined by Mary I. Slonina of KPMG.
Bryan’s session, “The Role of the Tax Advisor in the Tax System: Ethical and Penalty Standards for Advising Clients,” will take place on November 21st at 5:15 p.m. EST. He will be joined by Michael R. Stein of Hochman Salkin Toscher Perez P.C. and G. Michelle Ferreira of Greenberg Traurig.
The Institute on Federal Taxation is a six-day conference that offers practitioners the opportunity to earn over 40 hours of continuing education credits in a plethora of complex tax law topics. Session topics will include current developments in tax controversy, international taxation issues, trusts and estates, executive compensation and employee benefits, practice ethics, and more.
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.
About Bryan
Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.

2025 CBIT Fall Tax Day
2025-11-20 20:45 (America/New_York)
Megan L. Brackney will present a program on “Tax Controversy & Basics of Tax Procedure” at the 2025 Fall Tax Day hosted by the Committee of Banking Institutions on Taxation (CBIT).
The CBIT Fall Tax Day will be held on November 20, 2025, from 8:45 a.m. to 4:30 p.m. at the Arno Ristorante in New York, NY. Megan’s panel will be held at 2:30 p.m.
Learn more about the program 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. Megan is the Chair 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.

IRS Exam & Enforcement Trends: What Private Investment Funds Need to Know
2025-12-02 14:30 - 15:15 (America/New_York)
Caroline Ciraolo will join a panel titled IRS Exam & Enforcement Trends: What Private Investment Funds Need to Know, at the PIF Tax and Accounting Forum virtual conference on December 2, 2025, from 2:30 p.m. to 3:15 p.m. Eastern. Continuing education credit is available.
The panelists will address tax enforcement trends concerning partnerships and high-income taxpayers in light of recent changes at the IRS and areas of increased scrutiny that fund managers and investors should be mindful of. Attendees will learn how to effectively manage private investment fund audits and navigate re-established IRS guidance on investment entities.
Caroline will be joined by Jennifer Breen, partner at Morgan, Lewis & Bockius LLP, and Miri Forster, partner and National Tax Controversy & Dispute Resolution Leader at Eisner Advisory Group LLC.
You can learn more about the virtual 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.
