Caroline D. Ciraolo Participates In A Panel Entitled "IRS Compliance for Offshore Trusts and Gifts" At The 2022 Annual Meeting And Education Conference For The American Academy Of Attorney-CPAs
2022-06-25 10:00 - 11:15 (America/New_York)
On June 25, 2022, Caroline D. Ciraolo participates in a panel entitled “IRS Compliance for Offshore Trusts and Gifts” at the 2022 Annual Meeting and Education Conference for the American Academy Of Attorney-CPAs .
Description:
In January 2017, the IRS Large Business & International Division (“LB&I”) announced the first 13 compliance campaigns – issue-based examinations and deployments of resources to areas that present a level of risk or need for education. On May 21, 2018, LB&I announced the approval of the Form 3520/3520-A compliance and campus-assessed penalties campaign. This campaign was focused on the information returns associated with foreign trusts and foreign gifts and designed to “take a multifaceted approach to improving compliance with respect to the timely and accurate filing of information returns reporting ownership of and transactions with foreign trusts.” This panel reviews the foreign trust and foreign gift reporting obligations, the potential penalties and defenses, recent enforcement actions, and what lies ahead for taxpayers seeking to come into compliance.
Panelists:
Richard Chisholm, JD, WardChisholm LLP
Caroline D. Ciraolo, LLM, JD, Kostelanetz & Fink, LLP
Dan Rosefelt, Esq., CPA, Rosefelt Tax Law
Click here for more information and to register.

Caroline D. Ciraolo Moderates A Panel Entitled "Diversity in the Tax Bar" For The Law Firm Anti-Racism Alliance's Tax System Working Group Discussion Series
2022-07-20 14:00 - 15:30 (America/New_York)
Description: On July 20, 2022, Caroline D. Ciraolo moderates a panel entitled “Diversity in the Tax Bar” for the Law Firm Anti-Racism Alliance’s Tax System Working Group Discussion Series. The discussion series, which is operated in conjunction with the American College of Tax Counsel, the American Tax Policy Institute and the Tax Section of the American Bar Association, details 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. This panel discussion addresses recruiting and retaining diverse tax lawyers from the tax controversy practice.
Moderator:

Caroline D. Ciraolo, Kostelanetz & Fink LLP

Panelists:

Antoinette L. Ellison, Jones Day
Jenny L. Johnson, McDermott Will & Emery
Kelley C. Miller, Reed Smith LLP

Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!" At The 29th Annual Estate And Gift Tax Conference
2022-07-29 15:30 - 17:00 (America/New_York)
On July 29, 2022, Caroline D. Ciraolo participates in a panel entitled “Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!” at the 29th Annual Estate and Gift Tax Conference. MCLE credit is offered for this event.
Description:
We live in a global economy and many clients have sources of income, investments, assets, or activities outside the United States. For U.S. persons, this means having to comply with a complex web of reporting obligations under the Internal Revenue Code and the Bank Secrecy Act. This panel addresses the rules of the road with respect to foreign trusts and the receipt of gifts from foreign individuals and entities. The panelists address the reporting requirements, consequences of noncompliance, paths to compliance, recent enforcement actions and litigation, and best practices in challenging the often substantial penalties.
Speakers:
Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Kurt Kawafuchi, Lecturer of Accounting, University of Hawaiʻi at Mānoa Shidler College of Business
Marsha Dungog, Partner, Withersworldwide
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Don Fort Moderates A Panel Entitled "Illuminating the Shadow Economy: Using Publicly Available Data to Gain Visibility into Financial Crime" For ACFCS's Fincrime Virtual Week 2022
2022-08-04 09:00 - 10:00 (America/New_York)
On August 4, 2022, Don Fort moderates a panel entitled “Illuminating the Shadow Economy: Using Publicly Available Data to Gain Visibility into Financial Crime” for the Association of Certified Financial Crime Specialists’ Fincrime Virtual Week 2022.
Description: The evolving shadow economy – from short-term rentals to crypto and NFTs – poses significant challenges to regulators and investigators. However, practitioners can use publicly available data to gain actionable visibility into illicit business activity and potential financial crime. In this session, experts offer multiple perspectives from government and financial services on how to leverage publicly available data and open-source intelligence to combat financial crime and throw light on the shadows.
Moderator:

Don Fort, Director of Investigations, Kostelanetz and Fink, LLP

Panelists:

Jarod Koopman, Acting Executive Director, IRS Criminal Investigation / Cyber and Forensics Division
Matan Fattal, Co-Founder and CEO, IVIX
Teya Dyan, Fraud & Security Solutions, SAS

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Daniel Cady Davidson Participates In And Zenia Memon Moderates A Webinar Entitled "Careers in Tax Law" For The Federal Bar Association's Younger Lawyers Division And Section On Taxation
2022-08-05 14:00 - 15:00 (America/New_York)
Description: On August 5, 2022, Daniel Cady Davidson participates in and Zenia Memon moderates a webinar entitled “Careers in Tax Law” for the Federal Bar Association’s Younger Lawyers Division and Section on Taxation. Members of the Federal Bar Association, young tax practitioners, and aspiring students are invited to listen to a panel of tax practitioners speak about the nature of their jobs, their experience in different areas of tax law, and what young tax professionals and aspiring students might expect from a career in tax law.
Moderators:

Ege Berber, PwC
Zenia Memon, Kostelanetz & Fink LLP

Panelists:

Daniel Cady Davidson, Kostelanetz & Fink LLP
Teisha Ruggiero, Internal Revenue Service
Nick Zemil, PwC

Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "The Future of Voluntary Disclosures: Coming in From the Cold" For The CPA Academy
2022-08-23 16:00 - 17:00 (America/New_York)
On August 23, 2022, Caroline D. Ciraolo participates in a panel entitled “The Future of Voluntary Disclosures: Coming in From the Cold” for The CPA Academy.
Description:
For more than 70 years, the IRS maintained a voluntary disclosure policy designed to encourage taxpayers to come in from the cold and self-report non-compliance. In 2018, the voluntary disclosure program was updated to provide new procedures. In its most recent annual report, the Taxpayer Advocate Service noted that the new procedures are substantially more onerous and uncertain than the old procedures and may discourage taxpayers from stepping forward to self-disclose.
This session will discuss the latest voluntary disclosure developments, including the application of the updated program to cryptocurrency, and provide suggestions on how practitioners should advise their clients to make the best use of the new voluntary disclosure procedures. CPE credit is offered for this event.
Panelists:
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, LLP
Michel Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC
Phillip Colasanto, Attorney, Agostino & Associates
Daniel N. Price, Attorney at Law
Click here for more information and to register.

Megan Brackney Participates In A Panel Entitled "Coming in from the Cold: Dealing with Non-Filers" For The 2022 Forensic Accounting Summit: Forensic Accounting And Reconstruction
2022-08-25 08:40 - 10:00 (America/New_York)
On August 25, 2022, Megan Brackney participates in a panel entitled, “Coming in from the Cold: Dealing with Non-Filers” for the 2022 Forensic Accounting Summit: Forensic Accounting and Reconstruction.
Panel Description: The IRS is pursuing more than 10 million non-filers that they have already identified, plus countless others that get swept up in ongoing audits and investigations. For those taxpayers not yet contacted, interesting decisions await: to simply file or submit a request to be pre-cleared into voluntary disclosure? And which one is best for what situation? This panel of professionals will review the current state of voluntary disclosure, how to determine which option is best for the client, and how to bring them in without triggering a criminal referral.
Moderator:

Eric L. Green, Green & Sklarz LLC

Panelists:

Megan Brackney, Esq., Kostelanetz & Fink LLP
Laura L. Gavioli, Esq., Alston & Bird

Michael Sardar Moderates A Panel Entitled "The IRS Exam Process and Pitfalls for Taxpayers" For The 2022 Forensic Accounting Summit: Forensic Accounting And Reconstruction
2022-08-25 12:30 - 13:50 (America/New_York)
On August 25, 2022, Michael Sardar moderates a panel entitled, “The IRS Exam Process and Pitfalls for Taxpayers” for the 2022 Forensic Accounting Summit: Forensic Accounting and Reconstruction.
Panel Description: What do you do when your “routine” exam is no longer routine? This panel will review the usual audit process and discuss pitfalls that can arise, like indications of fraud, other crimes or false documents. The panel will also review what happens when it goes off the rails and what the practitioner can do to keep it moving in the right direction.
Moderator:

Michael Sardar, Kostelanetz & Fink LLP

Panelists:

Sanford J. Boxermann, Esq., Capes Sokol
Miri Forster, Eisner Advisory Group

Click here to register. CLE credit is being offered for this event.

Don Fort Participates In A Panel And Plenary Workshop Entitled "Professionals and the potential for abuse of trust – a US perspective" At The 39th Cambridge International Symposium On Economic Crime
2022-09-06 13:30 - 16:00 (America/New_York)
On September 6, 2022, Don Fort participates in a panel and plenary workshop entitled “Professionals and the potential for abuse of trust – a US perspective” at the 39th Cambridge International Symposium on Economic Crime at Jesus College, University of Cambridge, England.
Chair: Mr. Ian M. Comisky, Partner, Fox Rothschild LLP, Philadelphia and former Assistant US Attorney, Southern District of Florida, USA

Panelists:

Professor Barry Rider, Founder and Executive Director and Co-Chairman of the Symposium and Professorial Fellow, Centre of Development Studies, University of Cambridge, UK
Mr. Don Fort, Director of Investigations, Kostelanetz and Fink, LLP and former Chief, Criminal Investigations, Internal Revenue Service, US Department of Treasury, Washington DC, USA
Mr. Larry A. Campagna, Partner, Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, USA

Click here for more information.

Caroline D. Ciraolo Moderates A Panel Entitled "Getting your house in order – conducting internal investigation into alleged tax offenses” At The 39th Cambridge International Symposium On Economic Crime
2022-09-06 16:15 - 17:15 (Europe/London)
On September 6, 2022, Caroline D. Ciraolo moderates a panel entitled “Getting your house in order – conducting internal investigation into alleged tax offenses” at the 39th Cambridge International Symposium On Economic Crime at Jesus College, University of Cambridge, England.
Panel Description: With the increasing threat of Government enforcement, data leaks, and whistleblower complaints, companies need an established and effective protocol for investigating alleged violations of local or international laws. Particularly when dealing with potential tax violations, the failure to conduct a thorough and careful internal investigation can result in substantial monetary and other penalties and personal exposure for individuals involved. Panelists from England, France, and the United States will share their experience leading and managing internal investigations involving potential tax violations, review some of the difficult issues presented in dealing with officers, employees, and external witnesses, and best practices.
Moderator
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, LLP
Panelists
Polly Sprenger, Partner, Katten Muchin Rosenman LLP
Sandra R. Brown, Principal, Hochman Salkin Toscher Perez P.C.
Alice Rousseau, Partner, Rousseau and Sussman Advocates
Click here for more information and to register.

Bryan C. Skarlatos Participates In A Panel Discussion Entitled “Attorney-Client and Work Product Protections: What Will Remain After The Latest Government and Non-Government Initiatives"
2022-09-29 16:00 - 17:00 (America/Los_Angeles)
On September 29, 2022, Bryan C. Skarlatos participates in a panel discussion entitled “Attorney-Client Privilege and Work Product Protections: What Will Remain After The Latest Government and Non-Government Initiatives.”
Description: The Gatekeeper Initiative proposes to require some attorneys to evaluate and possibly “turn in” their clients. This program will discuss the history of the attorney-client and work product protections, current case law limiting the privilege as well as current American Bar Association and proposed legislative initiatives which would result in extraordinary changes in the attorney-client relationship. This program will cover the following topics:

Discuss the attorney-client privilege and work product protections
Review historical case law with respect to the privilege and protection
Discuss recent case law limiting the privilege
Explore proposed legislation with respect to attorney disclosures
Predict the effect of proposed changes on the attorney-client relationship

Panelists

Ian Comisky, icomisky@foxrothschild.com
Bryan C. Skarlatos, bskarlatos@kflaw.com

Stephen A. Josey Participates In A Panel Entitled “Diversity in the Tax Bar” For The Law Firm Anti-Racism Alliance's Tax System Working Group Discussion Series
2022-09-30 14:00 - 15:30 (America/New_York)
On September 30, 2022, Stephen A. Josey participates in a panel entitled “Tax System Working Group Discussion Series: Diversity in the Tax Bar” for the Law Firm Anti-Racism Alliance.
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, has organized a ten-part discussion series on diversity in the tax bar. Please join us for the final installment of this series to hear the four LFAA Tax System Working Group reporters discuss what they learned over the course of the first nine sessions, followed by a keynote speech from U.S. Tax Court Judge Maurice B. Foley. Whether you are an established member of the tax bar, a young lawyer, or a law student, this is a must-attend event for everyone who cares about creating sustainable diversity, equity and inclusion strategies for the tax profession.
Moderator:

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

Panelists:

Sanessa Griffiths, Skadden, Arps, Slate, Meagher & Flom, LLP
Stephen Josey, Kostelanetz & Fink, LLP
Alyssa Pratt, Foley Hoag, LLP
Lena Qiu, Perkins Coie, LLP

Keynote Speaker:

Judge Maurice B. Foley, U.S. Tax Court

Click here for more information and to register.

Jay Nanavati Participates In A Panel For The DC Bar On The Corporate Transparency Act
2022-10-19 11:30 - 12:45 (America/New_York)
On October 19, 2022, Jay R. Nanavati addressed the DC Bar in a panel entitled “Corporate Transparency Act: Are You Ready?”.
Panel Description: When FinCEN recently issued its final regulations regarding who must report information under the Corporate Transparency Act, many practitioners shrugged and filed the story for future reading. While the regulations will not go into effect until January 1, 2024, there will be significant ground for reporting companies and their advisors to cover to prepare for the new reporting regime. What exactly is this new beneficial ownership database? Who must report, what information, and when? Come hear from a panel of seasoned civil and criminal tax controversy attorneys who have been closely tracking the developments in this area.
Speakers:

Jay Nanavati, Partner, Kostelanetz & Fink LLP
Joseph Rillotta, Member, Miller & Chevalier
Melissa Wiley, Member, Caplin & Drysdale, Chartered

Click here for more information.

Don Fort Joins A Panel Titled "Criminal Tax Trends" At The 2022 Freeman Law International Tax Symposium
2022-10-20 09:40 - 22:30 (America/New_York)
Don Fort joins a panel titled Criminal Tax Trends at the 2022 Freeman Law International Tax Symposium. The symposium assembles tax experts from across the world to discuss tax trends that are reshaping international taxation. It sets the stage for attorneys to learn about topics such as global tax reform, international civil penalty enforcement, transfer pricing development, cryptocurrency global enforcement trends, and cross-border tax planning opportunities.
Panelists:

Don Fort, Director of Investigations, Kostelanetz & Fink, LLP
Carolyn Schenck, IRS National Fraud Counsel and Assistant Division Counsel (International)
Nanette Davis, Senior Litigation Counsel, Department of Justice Tax Division

Click here to register.

Caroline D. Ciraolo Joins A Panel Titled "International Tax & Trade Investigations And Voluntary Disclosures" At The 2022 Freeman Law International Tax Symposium
2022-10-20 10:40 - 23:30 (America/New_York)
Caroline Ciraolo joins a panel titled “International Tax & Trade Investigations and Voluntary Disclosures” at the 2022 Freeman Law International Tax Symposium. The symposium assembles tax experts from across the world to discuss tax trends that are reshaping international taxation. It sets the stage for attorneys to learn about topics such as global tax reform, international civil penalty enforcement, transfer pricing development, cryptocurrency global enforcement trends, and cross-border tax planning opportunities.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Josh Wu, Counsel, Latham & Watkins LLP
Olga Torres, Managing Member, Torres Trade Law
Matthew Robert, Principal, Freeman Law

Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "From The Experts: Tax Controversy And Tax Litigation - Civil & Criminal Tax Update" At The 81st Institute On Federal Taxation
2022-10-23 13:15 - 15:45 (America/New_York)
Caroline D. Ciraolo participates in a panel titled “From The Experts: Tax Controversy And Tax Litigation – Civil & Criminal Tax Update” on October 23, 2022 at the 81st Institute on Federal Taxation in New York.
Panel Description: Join a leading group of tax controversy practitioners from both the private sector and the government in an open discussion regarding current IRS enforcement priorities, initiatives, and campaigns, including areas impacted by the Inflation Reduction Act of 2022 (IRA). The panel covers a broad range of topics that impact tax compliance and tax litigation, including an examination of recent cases, investigations, and programs – such as the IRS’s new Emerging Issues Group – that reflect the government efforts to target high risk areas of noncompliance, including the increased role that the IRS Collection Division plays in tax administration, as well as approaches to representing and defending clients who are the focus of such investigations.
Panelists:

Frank Agostino, Esq., Founder & President, Agostino & Associates, PC, Hackensack, NJ
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
Kristina L. Rico, Esq., Senior Counsel, Office of Chief Counsel, Small Business/Self-Employed Division, National Fraud Counsel Team, Internal Revenue Service, Philadelphia, PA

Click here to register.

Garrett L. Brodeur Participates In A Panel Entitled "Exploring Tax Practice Settings With Alumni" For Students Of The Georgetown Law Center Tax LL.M. Program
2022-10-25 12:00 - 13:00 (America/New_York)
Garrett L. Brodeur participates in a panel titled “Exploring Tax Practice Settings With Alumni” for students of the Georgetown Law Center Tax LL.M. Program on October 25, 2022.
Panelists:

Garrett L. Brodeur, Kostelanetz LLP
Ballinger Doyle, Grant Thornton
Camilah Gould-Bailey, Google Tax
Saiya Savooji, KPMG Canada

This panel was only available to students of the Georgetown Law Center Tax LL.M. Program. Click here to view a recording of the panel.

Megan L. Brackney Participates In A Panel Entitled "When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice" At The 81st Institute On Federal Taxation
2022-10-27 17:15 - 18:55 (America/New_York)
Megan L. Brackney participates in a panel titled “When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice” on October 27, 2022 at the 81st Institute on Federal Taxation in New York.
Panel Description: How sure do you have to be before you tell a client it is okay to take a deduction or defer income? Do you have to audit a client’s records or can you just 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? When do you have to worry about conflicts of interest? While the answers to these questions may not always be clear, the law and related ethical standards provide very specific rules to help find the answers. This panel of expert practitioners addresses these and other thorny ethical issues that arise in everyday tax practice through the use of hypothetical examples. This program is essential for tax professionals who want to stay on the right side of the line.
Panelists:

Megan L. Brackney, Esq., Partner, Kostelanetz, New York, NY
Christopher S. Rizek, Esq., Member, Caplin & Dysdale, Chartered, Washington, DC

Click here to register.

Caroline D. Ciraolo Participates In A Panel Titled "Current Tax Disputes Trends at a Domestic and Cross Border Level" At The October IFA UK Branch Meeting
2022-10-27 18:00 - 19:30 (Europe/London)
Caroline D. Ciraolo joins a panel titled “Current Tax Disputes Trends at a Domestic and Cross Border Level” at the International Fiscal Associations UK branch meeting held on October 27, 2022.
Panel Description:
Panelists from around the world offer their unique perspectives on civil and criminal tax enforcement and trends in the United Kingdom, United States, Israel, India, and Finland.
Panelists:

Liesl Fichardt, Head of International Tax and Regulatory Investigations and Disputes, Quinn Emanuel, UK
Parul Jain, Co-Head, International Tax Practice, Nishith Desai Associates, India
Ofer Granot, Partner, Herzog, Fox & Neeman, Israel
Caroline Ciraolo, Partner, Kostelanetz LLP, Washington, DC
Jouni Weckström, Partner, Waselius & Wist, Finland

Click here for more information.

Three K&F Attorneys Participate In Ethics Panels At The "Tax Strategies 2022" Conference
2022-10-28
Bryan Skarlatos, Caroline Ciraolo, and Megan Brackney serve as panelists at the Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2022 (“Tax Strategies 2022”) conference. The panel is titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know.”
Mr. Skarlatos serves as a panelist at the New York City Tax Strategies 2022 conference on October 28, 2022. Ms. Brackney speaks at the Chicago conference on November 18, 2022, and Ms. Ciraolo presents at the Los Angeles conference on December 9, 2022.
Panel Description:
Ethical 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; 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
Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Tax Treaties For The Estate Planner" At The California Lawyers Association Taxation Section's 2022 Annual Meeting Of The Tax Bar And Tax Policy Conference
2022-11-04 15:30 - 17:00 (America/Los_Angeles)
Caroline D. Ciraolo participates in a panel entitled “Tax Treaties for the Estate Planner” at the California Lawyers Association, Taxation Section’s 2022 Annual Meeting of the Tax Bar and Tax Policy Conference. The panel will discuss important issues under income, and estate and gift tax treaties. It will also cover the exchange of information under such treaties and/or FATCA agreements and other associated issues.
Panelists:

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

Click here to register. Please note that MCLE credit is being offered for this event.

Caroline D. Ciraolo Participates In A Panel Titled "Using the IRS's Taxpayer Advocate Service to Help Taxpayers Across the Country" At The 59th Annual Hawaii Tax Institute
2022-11-07 16:00 - 17:00 (Pacific/Honolulu)
Caroline D. Ciraolo joins a panel titled “Using the IRS’s Taxpayer Advocate Service to Help Taxpayers Across the Country” at the 59th Annual Hawaii Tax Institute. This panel will discuss how the IRS’s National Taxpayer Advocate can help taxpayers address federal tax issues and mitigate taxpayer problems. Explore the internal workings of the IRS’ Taxpayer Advocate Service, the kind of facts and cases they address/resolve, and how all federal taxpayers and their Wealth Transfer Advisors can use this “voice of the taxpayer”.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Kurt Kawafuchi, Principle, Law Offices of Kurt Kawafuch
Erin M. Collins, National Taxpayer Advocate, Internal Revenue Service

Click here to register. Please note the event will be taking place in PST time.

Caroline D. Ciraolo Participates In A Panel Titled "Foreign Trusts and Gifts - Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!" At The 59th Annual Hawaii Tax Institute
2022-11-08 13:30 - 14:30 (Pacific/Honolulu)
Caroline D. Ciraolo joins a panel titled “Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!” at the 59th Annual Hawaii Tax Institute.
We live in a global economy and many clients have sources of income and assets outside the United States. For U.S. persons, this means having to comply with a complex web of reporting obligations under the Internal Revenue Code and the Bank Secrecy Act. This panel will address reporting requirements for foreign trusts (including Australian Superannuation funds, Liechtenstein Anstalt, Mexican fideicomiso, Canada tax saving and retirement plans, Stiftungs, and Usufructs), and the receipt of gifts from foreign individuals and entities. Learn about the consequences of noncompliance, paths to compliance, and best practices in challenging the often substantial penalties.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Marsha Dungog, Partner, Withers Worldwide
Kurt Kawafuchi, Principle, Law Offices of Kurt Kawafuchi

Click here to register. Please take note that this event will take place in PST time.

Caroline D. Ciraolo and Don Fort Participate In A Panel Titled "When Aggressive Tax Planning Becomes Criminal Conduct" At The 59th Annual Hawaii Tax Institute
2022-11-10 12:30 - 13:30 (Pacific/Honolulu)
Caroline D. Ciraolo and Don Fort join a panel titled “When Aggressive Tax Planning Becomes Criminal Conduct” at the 59th Annual Hawaii Tax Institute.
High income taxpayers frequently look to minimize their tax burdens and tax professionals are only too happy to oblige with one planning structure or another. It is when these structures cross the line that the Government sounds the alarm. When tax-advantaged transactions are “too good to be true,” “lack economic substance,” “lack business purpose,” or are deemed to be economic scams, taxpayers and their advisors can face civil audits and promoter investigations, both resulting in substantial civil penalties, professional licensing issues, and injunctions. When the Government believes that the individuals involved intentionally violated the rules – lying, cheating, or stealing – the matter can quickly move into the criminal realm. This panel will review what causes the Government to initiate a criminal tax investigations, ethical considerations for wealth transfer advisors, the roles of IRS-CI, the Justice Department’s Tax Division, and the U.S. Attorney’s Office, the transactions and structures currently targeted by the IRS, and “ripped from the headlines” criminal tax prosecutions.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Don Fort, Director of Investigations, Kostelanetz LLP
Evan Davis, Principal, Hochman Salkin Toscher Perez PC
Rebecca Perlmutter, AUSA, U.S. Attorney’s Office, District of Hawaii

Click here to register. Please note the event will be taking place in PST time.

Bryan C. Skarlatos Participates In A Panel Discussion Entitled "Criminal Tax Enforcement" At The UCLA Extension 38th Annual Tax Controversy Institute
2022-11-14 11:00 - 19:50 (America/New_York)
Bryan C. Skarlatos participates in a panel discussion entitled “Criminal Tax Enforcement” on October 27th at the UCLA Extension 38th Annual Tax Controversy Institute. The virtual re-broadcast is available on November 14, 2022.
Panel Description:
This panel covers criminal tax proceedings arising under the Internal Revenue Service’s laws, including the roles of the criminal tax attorney, tax fraud investigations, and IRS criminal investigations.
Moderator:

Sandra R. Brown, Hochman Salkin Rettig Toscher & Perez, P.C.

Panelists:

Bryan C. Skarlatos, Esq., Kostelanetz LLP
Tyler R. Hatcher, IRS-CI Special Agent in Charge, Los Angeles Field Office
Damon Rowe, Meadows Collier Reed Cousins Crouch & Underman, LLP
Lorraine Yu, IRS Chief Counsel, Criminal Tax Counsel

Click here to register for the virtual re-broadcast.

Garrett L. Brodeur Speaks About Current Supreme Court Case, Bittner v. United States, At The ABA Tax Section Administrative Practice Committee November Meeting
2022-11-17 12:00 - 13:00 (America/New_York)
Garrett L. Brodeur speaks about the current Supreme Court case, Bittner v. United States (No. 21-1195), at the ABA Tax Section Administrative Practice Committee’s Monthly Lunch Meeting on November 17, 2022. The presentation will focus on the oral arguments heard before the Court on the morning of November 2nd, 2022.
Meeting Description: The meeting will cover updates on the following important and closely-watched cases:

U.S. v. Bittner, No. 21-1195: Is a “violation” under the Bank Secrecy Act the failure to file an annual FBAR or is there a separate violation for each individual account that was not properly reported. The Supreme Court heard oral arguments on November 2, 2022.
Green Valley Investors, LLC, 159 T.C. No. 5 (November 9, 2022): The US Tax Court held that the IRS could not impose penalties for failure to comply with Notice 2017-10, designating conservation easements as listed transactions, because the Notice skipped notice-and-comment rulemaking required under the Administrative Procedure Act.
In re Grand Jury Proceeding, No. 21-1397. On October 3, 2022, the Supreme Court granted certiorari to consider if a communication involves both legal and non-legal advice, when is it protected from disclosure by the attorney-client privilege?

Speakers:

Garrett L. Brodeur, Kostelanetz LLP, Co-Counsel for Amicus Curiae American College of Tax Counsel.
Susan Combs, Holland & Hart LLP.

Caroline D. Ciraolo Presents "Ethics: When Aggressive Tax Planning and Controversy Defense Become Criminal Conduct" At The 71st Tulane Tax Institute
2022-11-17 16:45 - 17:45 (America/New_York)
Caroline D. Ciraolo speaks on “Ethics: When Aggressive Tax Planning and Controversy Defense Become Criminal Conduct” at the 71st Tulane Annual Tax Institute on November 17th, 2022.
Taxpayers frequently look to minimize their tax burdens or avoid immediate payment of tax liabilities and tax professionals often assist with a variety of planning structures or defensive strategies. It is when these structures or strategies cross the line that the Government sounds the alarm. On the civil side, tax-advantaged transactions or aggressive collection strategies that are “to good to be true,” “lack economic substance,” or “lack business purpose” can result in substantial civil penalties, professional licensing issues, and injunctions. When the Government believes that the individuals involved intentionally violated the rules – lying, cheating, or stealing – the matter can quickly move into the criminal realm. This panel will review what causes the Government to initiate a criminal tax investigation, the roles of IRS-CI, the Justice Department’s Tax Division, and the U.S. Attorney’s Office, the transactions and structures currently targeted by the IRS, and “ripped from the headlines” criminal tax prosecutions.
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Bryan C. Skarlatos Participates In A Panel Entitled "When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice" At The 81st Institute On Federal Taxation
2022-11-17 20:15 - 21:55 (America/New_York)
Bryan C. Skarlatos chairs a panel titled “When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice” on November 17, 2022 at the 81st Institute on Federal Taxation in San Diego, California.
Panel Description: How sure do you have to be before you tell a client it is okay to take a deduction or defer income? Do you have to audit a client’s records or can you just 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? When do you have to worry about conflicts of interest? While the answers to these questions may not always be clear, the law and related ethical standards provide very specific rules to help find the answers. This panel of expert practitioners addresses these and other thorny ethical issues that arise in everyday tax practice through the use of hypothetical examples. This program is essential for tax professionals who want to stay on the right side of the line.
Panelists:

Chair: Bryan C. Skarlatos, Esq., Partner, Kostelanetz LLP, New York, NY
Michael J. Desmond, Esq., Partner, Gibson, Dunn & Crutcher, Los Angeles, CA and Washington, DC
Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

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Megan L. Brackney Participates In A PLI Panel Entitled "Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know"
2022-11-18 13:15 - 14:15 (America/Chicago)
Megan L. Brackney participates in a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” on November 18, 2022 at the Practicing Law Institute’s Tax Strategies 2022 program.
Panel Description: Panelists discuss ethical 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. Additionally, panelists describe 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:

Megan L. Brackney
Jenny L. Johnson
Bradley M. Seltzer

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Caroline D. Ciraolo Moderates A Panel Titled "From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime" At The 2022 IRS Representation Conference
2022-11-18 13:45 - 14:45 (America/New_York)
Caroline D. Ciraolo moderates a panel titled “From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime” at the 2022 IRS Representation Conference.
Panel Description: Audits of partnerships were previously governed by special procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). At the start of the 2018 tax year, partnership audits became governed by the new Centralized Partnership Audit Regime. The new regime is dramatically changing the way audits are handled and practitioners must understand the new rules to effectively represent their clients and avoid costly mistakes. This panel will discuss the differences between TEFRA and the BBA, and preparing for and effectively managing a partnership audit under the new rules.
Moderator:

Caroline D. Ciraolo, Esq., Kostelanetz LLP, Washington, DC

Panelists:

Philip J. Wilson, CPA, Marcum, LLP, Costa Mesa, CA
Steven Hurok, Esq., Citrin Cooperman & Company LLP, New York, NY
G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA

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