Caroline D. Ciraolo Participates In A Panel Entitled "State, Local, and International Collection of Tax" For The 7th International Conference On Taxpayer Rights
2022-05-19 10:00 - 11:30 (America/New_York)
On May 19, 2022, Caroline D. Ciraolo participates in a panel entitled “State, Local, and International Collection of Tax” at the 7th International Conference on Taxpayer Rights: Tax Collection & Taxpayer Rights in the Post-COVID World, hosted by the Center for Taxpayer Rights.
Description:
This panel examines the European and US experience with conflicts of law and procedures between different states and localities with respect to the collection of tax. Information-sharing and the authority and ability of countries to reach assets in another country are discussed, as well as the availability of inter-governmental dispute resolution in the collection arena.
Moderator:

Joshua Odintz, Holland & Knight, United States

Panelists:

Caroline D. Ciraolo, Kostelanetz & Fink, LLP, United States
Katerina Perrou, Post-Doctoral Researcher and Lecturer in Tax Law, National and Kapodistrian University of Athens; Legal Counsel to the Governor of the IAPR, Greece
Luk Vandenberghe, Head of Sector Tax Enforcement and Mutual Assistance, European Commission, Taxation & Customs Union Directorate General, Belgium

Click here for more information and to register.

Megan L. Brackney Participates In A Panel Entitled “Coming in from the Cold: Dealing with Non-Filers” For The TRN's Forensic Accounting Summit
2022-05-20 08:40 - 10:00 (America/New_York)
On May 20, 2022, Megan L. Brackney participates in a panel entitled, “Coming in from the Cold: Dealing with Non-Filers” for the Forensic Accounting Summit, an all-day program hosted by the Tax Rep Network.
Event Description: Taxes are at the heart of our economic engine. Though we have a “voluntary tax system,” it’s not THAT voluntary! The IRS makes a point of pursuing taxpayers who fail to uphold their end of the bargain and is currently pursuing the more than 10 million non-filers, many of whom are high-income earning. This full-day conference will bring experts from around the country together to review how the process works to bring in non-filers, handle the IRS, and what to watch out for to protect yourself from ethical pitfalls. It will also review reconstruction techniques that come up far too often in bankruptcies, divorce, and civil and criminal tax matters, with an emphasis on how to present the information to the IRS. Finally, we will review how to lay the groundwork early to avoid or abate penalties when these issues arise.
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? Our 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, Esq., Green & Sklarz LLC

Panelists

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

Click here for more information and to register.

Christopher M. Ferguson Teaches A Course Entitled “Walking on Eggshells: How to Handle An Eggshell Audit” For The CPA Academy
2022-05-24 18:00 - 19:00 (America/New_York)
On May 24, 2022, Christopher M. Ferguson teaches a course entitled, “Walking on Eggshells: How to Handle An Eggshell Audit” for the CPA Academy. CLE and CPE credit is offered for this event.
Course Description: An IRS audit can be a harrowing experience under any circumstances. When there is the risk of a criminal referral, otherwise known as an “eggshell audit,” the stakes increase drastically. This presentation covers many of the unique aspects of eggshell audits, including; (i) how to handle Information Document Requests and dealings with the civil exam agent; (ii) how to recognize badges of fraud; (iii) how and when to assert a client’s Fifth Amendment rights; (iv) how to handle ongoing tax compliance in the midst of an eggshell audit; (v) how to conduct a “shadow audit” while preserving privilege; and (vi) how to recognize that a criminal referral is being contemplated or has been made. The presentation also includes practice tips for navigating an eggshell audit ethically while trying to prevent the eggs from breaking.
Presenter:

Christopher M. Ferguson, Partner, Kostelanetz & Fink LLP

Megan L. Brackney Participates In A Panel Entitled “Ethics in 2022: Privilege on Trial, Practice on the Move” For The 50th Annual Conference Of The USA Branch Of The International Fiscal Association
2022-06-03 15:45 - 16:45 (America/New_York)
On June 3, 2022, Megan L. Brackney participates in a panel entitled, “Ethics in 2022: Privilege on Trial, Practice on the Move” for the 50th Annual Conference of the USA Branch of the International Fiscal Association.
Event Description: The 50th Annual Conference of the USA Branch of the International Fiscal Association includes two full days, Thursday, June 2 and Friday, June 3, of substantive sessions on international tax topics, featuring prominent speakers from private practice, industry, and government. At the conclusion of this program, participants will be able to:

Discuss the technical aspects of recent changes in US tax rules in various specialty areas. Examples are BEAT, the FTC and GILTI.
Discuss what is coming from the OECD, Congress, and other countries. Focus will be on Pillars I and II.
Engage in effective tax planning for client and employers, especially re. cryptocurrency, dispute resolution, IRS guidance, and reliance on tax treaties.

Panel Description: The “Ethics in 2022: Privilege on Trial, Practice on the Move” panel will discuss two core ethics issues that demand a fresh look in 2022: the availability of attorney-client privilege protection and the significance of practice limitations. The 9th Circuit rejected assertions of privilege by an international tax law firm regarding attorney-client communications involving legal and nonlegal advice. What could the court’s ruling, which is now on appeal to the Supreme Court, mean for attorney-client relations? Are other protections available? How can lawyers best protect their clients going forward – and what additional concerns arise cross-border? Also new in 2022 is the permanency of long-term hybrid and remote work. What initially emerged as a temporary pandemic response has become a workplace commitment in many firms. Now these firms need to take a careful look at practice of law limitations, in the US and beyond.
Moderator:

Diane Ring, Boston College

Panelists

Megan L. Brackney, Esq., Kostelanetz & Fink, LLP;
Amanda Leon, Caplin & Drysdale

CPE credit may be offered for this event.
Click here for more information and to register.

Bryan C. Skarlatos Participates In A Panel Discussion Entitled “Corporate Transparency Act: Reporting of Real Estate Transactions and other Bank Secrecy Act Amendments Affecting Tax Practitioners"
2022-06-08 12:00 - 13:00 (America/Los_Angeles)
On June 8, 2022, Bryan C. Skarlatos participates in a panel discussion entitled “Corporate Transparency Act: Reporting of Real Estate Transactions and other Bank Secrecy Act Amendments Affecting Tax Practitioners” hosted by The Florida Bar Association.
Description: This program will cover the following topics:

Overview of selected portions of the AML Act of 2020.
Changes to cryptocurrency rules.
Regulation of antiquities and possibly artwork.
Criminal law statutory additions and penalty changes.
Corporate Transparency Act.
2022 Regulatory Initiatives.

Panelists

Ian Comisky, icomisky@foxrothschild.com
Lester M. Joseph, lester.m.joseph@wellsfargo.com
Bryan C. Skarlatos, bskarlatos@kflaw.com

Click here for more information and to register.

Sharon L. McCarthy Participates In A Panel Entitled "The Criminal Tax Case From Start to Finish" At The 2022 IRS Representation Conference
2022-06-10 09:30 - 10:30 (America/New_York)
On June 10, 2022, Sharon L. McCarthy participates in a panel entitled “The Criminal Tax Case From Start to Finish” at the 2022 IRS Representation Conference.
Description:
This panel reviews how criminal tax cases get started, how cases are worked, and what the process is from start to finish. The panel focuses on the role of the Kovel accountant and when the Kovel arrangement works and does not work.
Moderator:
Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Panelists:
Sharon McCarthy, Esq., Kostelanetz Fink LLP, New York, NY
Maria Papageorgiou, Special Agent, IRS Criminal Investigation, Bridgeport, CT
Kristen Rico, Esq., Senior Counsel, IRS Office of Chief Counsel, Internal Revenue Service, Philadelphia, PA
Click here for more information.

Sharon L. McCarthy Participates In A Panel Entitled "When Failure to File a Return Becomes Criminal" At The 2022 IRS Representation Conference
2022-06-10 15:30 - 16:30 (America/New_York)
On June 10, 2022, Sharon L. McCarthy participates in a panel entitled “When Failure to File a Return Becomes Criminal” at the 2022 IRS Representation Conference.
Description:
This panel reviews the fundamentals of representing taxpayers in civil tax controversy by focusing on representing taxpayers who have failed to file tax returns. The program provides an overview of the key statutes and procedures, including potential penalties, and available defenses. The discussion reviews what causes the failure to file a return or several returns to move from a civil issue to a criminal issue, and what federal prosecutors look for when determining to pursue the issue as a criminal violation.
Moderator:
Barbara Kaplan, Esq. Greenberg Traurig, LLP, New York, NY
Panelists:
Sharon McCarthy, Esq., Kostelanetz Fink LLP, New York, NY
Anastasia King, Assistant United States Tax Attorney, Department of Justice, New Haven, CT
Maria Papageorgiou, Special Agent, IRS Criminal Investigation, Bridgeport, CT
Click here for more information.

Caroline D. Ciraolo Co-Chairs A Panel Entitled "Criminal Tax Update" At The 14th Annual U.S. and Latin America Tax Practice Trends Conference
2022-06-16 13:30 - 15:00 (America/New_York)
On June 16, 2022, Caroline D. Ciraolo co-chairs a panel entitled “Criminal Tax Update” at the 14th Annual U.S. and Latin America Tax Practice Trends Conference, hosted by the ABA Section of Taxation, the International Bar Association (Taxes Committee), and the International Fiscal Association – USA Branch.
Conference Description:
Returning to the Mandarin Oriental Miami after a two-year hiatus, the 14th Annual U.S. and Latin America Tax Practice Trends Conference focuses on practical tax practice trends for multinational corporations and their international advisors and provides insight into how government tax officials may view the international tax landscape in light of important international developments that impact corporate taxpayers. Panelists include industry leaders, senior government and OECD officials, and leading tax practitioners from the United States and Latin America.
Click here for more information and to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Coming in From the Cold: The Future of Voluntary Disclosures" At The 14th Annual NYU Tax Controversy Forum
2022-06-24 14:45 - 15:45 (America/New_York)
On June 24, 2022, Caroline D. Ciraolo participates in a panel entitled “Coming in From the Cold: The Future of Voluntary Disclosures” at the 14th Annual NYU Tax Controversy Forum.
Description:
For more than 70 years, the IRS has maintained a voluntary disclosure policy designed to encourage taxpayers to come in from the cold and self-report noncompliance. 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 actually discourage taxpayers from stepping forward to self-disclose. This panel discusses the latest voluntary disclosure developments, including the application of the updated program to cryptocurrency, and provides suggestions on how practitioners should advise their clients to make the best use of the new voluntary disclosure procedures.
Moderator:
Phillip Colasanto, Esq., Associate, Agostino & Associates, PC, Hackensack, NJ
Panelists:
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
Mark Matthews, Esq., Member, Caplin & Drysdale, Washington, DC
Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
Click here for more information and to register.

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
Click here for more information and to register.

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

Click here for more information and to register.

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

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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

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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
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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.
