Megan L. Brackney Participates In A PLI Panel Entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know”
2021-11-11 14:15 - 15:15 (America/New_York)
On November 11, 2021, Megan L. Brackney participates in a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know” for “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021” hosted by the Practising Law Institute (PLI).
Description: “Tax Strategies 2021” focuses on the tax issues presented by the entire spectrum of modern major corporate transactions, from single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. In their panel, Megan L. Brackney, Jenny L. Johnson Ware, Bradley M. Seltzer, and Sharyn M. Fisk (Invited) discuss ethics rules related to advising clients on corporate transactions, including tax motivated transactions and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit. They also discuss the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Speakers

Megan L. Brackney, Partner, Kostelanetz & Fink, LLP
Jenny L. Johnson Ware, Partner, McDermott Will & Emery, LLP
Bradley M. Seltzer, Partner, Eversheds Sutherland
Sharyn M. Fisk (Invited), Director, Office of Professional Responsibility, Internal Revenue Service

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Caroline D. Ciraolo And Don Fort Participate In A Panel Entitled “Enforcement Priorities: High-Income Non-Filers & High Wealth Taxpayers”
2021-11-15 12:50 - 14:05
On November 15, 2021, Caroline D. Ciraolo and Don Fort participate in a panel entitled “Enforcement Priorities: High-Income Non-Filers & High Wealth Taxpayers.” This panel is part of the AICPA 2021 National and Sophisticated Tax Planning Conference.
Description: Since March 2020, the IRS has elevated fraud enforcement to new heights with the establishment of the Office of Fraud Enforcement, led by a former IRS Criminal Investigation Special Agent in Charge and Director of International Operations; appointment of National Fraud Counsel; and creation of the Office of Promoter Investigations, led by a veteran of the IRS with extensive experience managing investigations and examinations involving abusive transactions. The IRS also has enhanced fraud training efforts across the IRS operating divisions, reinforced fraud referral procedures with subject matter experts, announced new compliance campaigns, and initiated parallel proceedings targeting taxpayers and professional enablers participating in abusive tax avoidance schemes. Priority areas include, but are not limited to, high income non-filers, micro-captive insurance, syndicated conservation easements, virtual currency, the gig economy, and Puerto Rico residency programs. This session will discuss the current state of enforcement against high income/high wealth taxpayers and what we can expect in the days to come.
Speakers

Don Fort, CPA, Director of Investigations, Kostelanetz and Fink, LLP
Caroline D. Ciraolo, LL.M. (Taxation), Partner, Kostelanetz and Fink, LLP
Darren Guillot, Commissioner, Small Business/Self Employed Collection, IRS

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Bryan C. Skarlatos Chairs A Panel Entitled “Crossing the Line: Real Life Ethical Issues in Tax Practice" At The NYU Institute On Federal Taxation
2021-11-16 11:30 - 13:30
On November 16, 2021, Bryan C. Skarlatos chairs a panel entitled “Crossing the Line: Real Life Ethical Issues in Tax Practice” at the NYU Institute on Federal Taxation.
Description: Tax practice can be split into three different categories: tax planning, tax return preparation and audit/trial representation. Each stage has its own ethical considerations. Before you file a tax return, how sure do you have to be before you can tell a client it is okay to take a deduction or characterize income as capital gain? 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? This panel of expert practitioners will address 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 stay on the right side of the line.
Chair:

Bryan C. Skarlatos, Partner, Kostelanetz & Fink

Speakers:

Miriam L. Fisher, Latham & Watkins, LLP
Sharyn Fisk, Director, Internal Revenue Service, Office of Professional Responsibility

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Caroline D. Ciraolo Interviews Darren Guillot And De Lon Harris In A Panel On IRS Enforcement Updates At The IRS Representation Conference
2021-11-18 08:40 - 10:45
On November 18, 2021, Caroline D. Ciraolo interviews Darren Guillot and De Lon Harris, Commissioners of the IRS Small Business/Self-Employed Division during a panel on IRS Enforcement Updates. This panel is part of the 2021 IRS Representation Conference: The Nuts & Bolts of a Tax Representation Practice.
Description: Voluntary compliance and enforcement of the tax laws are at the heart of our tax system. Over the past several years, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers report and pay the correct amount of tax. These panel interviews provide us with an update on new developments at the IRS.
Panelists:

Darren Guillot, Commissioner, Small Business/Self Employed Division, IRS
De Lon Harris, Commissioner, Small Business/Self Employed Division, IRS

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Claude M. Millman Participates In A Panel Entitled “What to Know About Doing Business in New York" At City & State New York's 2021 Virtual Government Procurement Conference
2021-11-18 13:30 - 14:25
On November 18, 2021, Claude M. Millman participates in a panel entitled “What to Know About Doing Business in New York” at City & State New York’s 2021 Virtual Government Procurement Conference.
Description: This panel provides an inside look at the New York procurement process and prepares vendors to navigate the system now and in a post-COVID world. Topic areas include strategies for dealing with potential challenges, including the possibility of another COVID wave, tips for winning the bidding process, understanding the complexity of RFPs, and insights into what NY government entities want from potential contractors
Moderator:

Rebecca Lewis, Reporter, City & State NY

Speakers:

Mersida Ibric, Deputy Commissioner for Citywide Procurement, NYC Department of Citywide Administrative Services
Jennifer Geiling, Deputy Director, Policy and Partnerships New York City Mayor’s Office of Contract Services
Claude M. Millman, Partner, Kostelanetz & Fink, LLP
Michael Garner, MBA, Chief Diversity & Inclusion Officer, Metropolitan Transportation Authority

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Michael Sardar Participates In A Panel Entitled “Tax Liens 101: Mechanics and Impact of the Federal Tax Lien, and What to Do With It?” At The IRS Representation Conference
2021-11-18 14:00 - 15:00
On November 18, 2021, Michael Sardar participates in a panel entitled “Tax Liens 101: Mechanics and Impact of the Federal Tax Lien, and What to Do With It?” at the IRS Representation Conference.
Description: The IRS does not need to do anything to create a tax lien. IRC § 6321 creates a lien automatically when demand for payment is made and no payment is forthcoming. However, to protect its interest the IRS often files a Notice of Federal Tax Lien. This panel reviews the mechanics of how tax liens work and what their impact is on taxpayers. The panel also reviews the options for resolving the issue and the lien, such as discharging assets, having the IRS subordinate its lien to another creditor, and having the lien withdrawn.
Moderator:

Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:

Debra Reale, Esq., Green & Sklarz LLC, New Haven, CT
Steve I. Hurok, Esq., CPA, Citrin Cooperman, New York, NY
Michael Sardar, Esq., Kostelanetz & Fink, LLP, New York, NY

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Robert M. Russell Participates In A Panel Entitled “A Closer Look at GILTI and FDII” At The First Annual Freeman Law International Tax Symposium
2021-11-18 14:00 - 15:00
On November 18, 2021, Robert M. Russell participates in a panel entitled “A Closer Look at GILTI and FDII” at the First Annual Freeman Law International Tax Symposium.
Description: The Global Intangible Low Tax Income (GILTI) and Foreign Derived Intangible Income (“FDII”) categories were a product of the Tax Cuts & Jobs Act of 2017 (“TCJA”). GILTI portended a significant impact on Controlled Foreign Corporation (“CFCs”). FDII, on the other hand, created a tax preference incentivizing U.S. corporate taxpayers to serve foreign markets. Now several years into the TCJA, our panel takes a look back at these important provisions.
Speakers:

Robert M. Russell, Kostelanetz & Fink, LLP
Marissa Rensen, KPMG LLP

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Megan L. Brackney Co-Chairs A Panel Entitled “Update on the Centralized Partnership Audit Rules: Are You and Your Clients Ready?" At The NYU Institute On Federal Taxation
2021-11-18 16:00 - 18:00
On November 18, 2021, Megan L. Brackney co-chairs a panel entitled “Update on the Centralized Partnership Audit Rules: Are You and Your Clients Ready?” at the NYU Institute on Federal Taxation.
Description: Now that entities taxed as partnerships and their tax advisors have had three years to understand and put into place procedures as well as revisions to outstanding partnership and LLC operating agreements to adapt to the new partnership audit rule regime, the focus now turns to how tax audits, appeals, settlements, litigation, and appeals of adverse judicial determinations will work in “real time.” The co-chairs address problems associated with elections-out, understatement modifications, push-outs and pull-ins, as well as how partners can protect themselves from the partnership representative’s unilateral authority to settle out all partnership issues. Continuing applicability of the TEFRA audit rules for tax years beginning on or before 2017 also are discussed.
Co-Chairs:

Megan L. Brackney, Partner, Kostelanetz & Fink
Jerald David August, Partner, Fox Rothschild

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Caroline D. Ciraolo Participates In A Panel Entitled “Foreign Forms 101: The Forms Every Practitioner Should be Familiar With” At The IRS Representation Conference
2021-11-18 16:30 - 17:30
On November 18, 2021, Caroline D. Ciraolo participates in a panel entitled “Foreign Forms 101: The Forms Every Practitioner Should be Familiar With” at the IRS Representation Conference.
Description: With IRS enforcement around foreign assets and reporting continuing, and more and more taxpayers having reporting requirements, The IRS Representation Conference brings together some experts to walk through what international tax forms every tax practitioner should be aware of when they are assisting taxpayers comply.
Moderator

Lawrence A. Sannicandro, McCarter & English LLP, Newark, NJ

Panelists

Caroline D. Ciraolo, Esq., Kostelanetz & Fink, LLP, Washington, DC
Cecil Nazareth, ACA, CPA, MBA, Nazareth CPAs, Norwalk, CT

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Don Fort Participates In A Panel Entitled "The Pandora Papers and Data Leaks" At The First Annual Freeman Law International Tax Symposium
2021-11-19 10:00 - 11:00
On November 19, 2021, Don Fort participates in a panel entitled “The Pandora Papers and Data Leaks” at the First Annual Freeman Law International Tax Symposium.
Description: The event features a host of leading experts from across the world—including distinguished tax practitioners and government officials from the United States, Mexico, Brazil, and Latin America—who discuss international tax topics impacting taxpayers around the globe. Some of the topics discussed at the Symposium include Global Tax Reform, International Criminal Tax Enforcement, and Cross-Border Tax Planning Opportunities.
Panelists:

Don Fort, Director of Investigations, Kostelanetz and Fink, LLP
Alejandro Barrera, Partner, Basham, Ringe Y Correa, S.C
Amanda Barraza de Wong, Recognized International Tax Practitioner at Prestigious Panamanian law firm, Morgan & Morgan.
Brian McManus, Chair of Latham & Watkins’ Boston Tax Department

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Caroline D. Ciraolo Participates In A Panel Entitled "International Criminal Tax Enforcement" At The First Annual Freeman Law International Tax Symposium
2021-11-19 11:00 - 12:00
On November 19, 2021, Caroline D. Ciraolo participates in a panel entitled “International Criminal Tax Enforcement” at the First Annual Freeman Law International Tax Symposium.
Description: The event features a host of leading experts from across the world—including distinguished tax practitioners and government officials from the United States, Mexico, Brazil, and Latin America—who discuss international tax topics impacting taxpayers around the globe. Some of the topics discussed at the Symposium include Global Tax Reform, International Criminal Tax Enforcement, and Cross-Border Tax Planning Opportunities.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz and Fink, LLP
Sandra R. Brown, Partner, Hochman Salkin Toscher Perez P.C.
Eric Hylton, National Director of Compliance, alliantgroup

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Caroline D. Ciraolo Participates In An Interview With The ABA Tax Section's Women In Tax Forum
2021-11-19 16:30 - 17:30
On November 19, 2021, Caroline D. Ciraolo participates in an interview with the American Bar Association’s Women in Tax Forum. This interview is part of a Zoom Tea series and focuses on Caroline’s participation in the American Bar Association and her new role as Vice Chair of Diversity, Membership, and Inclusion.
Description: The Women in Tax Forum’s vision for the Zoom Tea series is to create a warm, positive space where women in tax share their experiences of success and overcoming struggles inside a community committed to inspiring and supporting one another to build thriving careers in tax.
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Caroline D. Ciraolo Participates In A PLI Panel Entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know”
2021-12-03 16:15 - 17:15
On December 3, 2021, Caroline D. Ciraolo participates in a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know” for “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021” hosted by the Practising Law Institute (PLI).
Description: “Tax Strategies 2021” focuses on the tax issues presented by the entire spectrum of modern major corporate transactions, from single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. In their panel, Sandra R. Brown, Caroline D. Ciraolo, Bradley M. Seltzer, and Sharyn M. Fisk discuss ethics rules related to advising clients on corporate transactions, including tax motivated transactions and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit. They also discuss the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Speakers

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Sandra R. Brown, Attorney, Hochman Salkin Toscher Perez P.C.
Bradley M. Seltzer, Partner, Eversheds Sutherland
Sharyn M. Fisk, Director, Office of Professional Responsibility, Internal Revenue Service

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The Law Firm Antiracism Alliance Hosts Second Discussion In Series Entitled “Diversity in the Tax Bar” As Part Of Its Tax System Working Group Discussion Series
2021-12-07 13:30 - 15:00
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Megan L. Brackney Participates In A Panel Entitled “Ethical Issues in International Tax Practice" At The 2nd Annual IFA USA Winter International Tax Conference
2021-12-09 11:00 - 12:00
On December 9, 2021, Megan L. Brackney participates in a panel entitled “Ethical Issues in International Tax Practice” at the 2nd Annual IFA USA Winter International Tax Conference.
Description: The 2nd Annual IFA USA Winter International Tax Conference is designed to provide a forum and encourage an exchange of views between government and private sector panelists, and is designed for:

Corporate tax executives responsible for international tax matters
Law firm partners and associates working in the international tax area
Accounting firm partners and managers working in the international tax area
Members of the academic community interested in the latest technical developments in international taxation
Government and other professionals working in international tax learning

The panel sessions will include:

Cryptocurrency developments, including new reporting regimes in the United States and abroad
LB&I hot topics in tax controversy
Legislative landscape in light of potential tax reform
International partnership planning issues
IP migration planning and pitfalls
OECD/G20 Inclusive Framework developments
Ethics

Objectives – At the conclusion of this program, participants will be able to:

Better understand pending legislative changes to the Code affecting international tax matters;
Discuss what is coming from the OECD under Pillars 1 and 2; and
Engage in effective tax planning for client and employers, especially re. dispute resolution, implementation of IRS guidance, and transactions involving IP.

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Caroline D. Ciraolo Participates In A Panel Entitled “Getting To 'No': What Works and What Doesn’t Work to Get the IRS and DOJ to Decline Prosecution" At The ABA's 38th Annual Criminal Tax Fraud Institute And 11th Annual Civil Tax Controversy Institute
2021-12-09 11:30 - 12:30
On December 9, 2021, Caroline D. Ciraolo participates in a panel entitled “Getting To ‘No’: What Works and What Doesn’t Work to Get the IRS and DOJ to Decline Prosecution” at the ABA’s 38th Annual Criminal Tax Fraud Institute and 11th Annual Civil Tax Controversy Institute.
Description: The surest way to win a criminal prosecution is not to have it brought at all. The government may decline to seek an indictment based on discretionary factors as well as the evidence. This panel will consider issues ranging from when to come forward and what is most likely to be persuasive in seeking declination.
Speakers:

Kelley C. Miller, [Introduction], Reed Smith, Washington, DC
Scott Michel, [Moderator], Caplin & Drysdale Chtd, Washington, DC
Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC
Richard T. Lunger III, Internal Revenue Service, Washington, DC
Sarah E. Paul, Eversheds Sutherland, New York, NY

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Bryan C. Skarlatos Moderates And Jordan L. Weatherwax Introduces A Panel Entitled “Common Yet Challenging Ethical Questions" At The ABA's 38th Annual Criminal Tax Fraud Institute And 11th Annual Civil Tax Controversy Institute
2021-12-09 16:50 - 18:00
On December 9, 2021, Bryan C. Skarlatos moderates and Jordan L. Weatherwax introduces a panel entitled “Common Yet Challenging Ethical Questions” at the ABA’s 38th Annual Criminal Tax Fraud Institute and 11th Annual Civil Tax Controversy Institute.
Description: Ethical considerations are part of everyday practice, but some issues can be more challenging than others. This panel will consider a series of hypotheticals to focus on the ethical concerns that tax practitioners may encounter.
Moderator:

Bryan C. Skarlatos, Kostelanetz & Fink

Speakers:

Jordan L. Weatherwax, Kostelanetz & Fink
Sharyn Fisk, Internal Revenue Service
Hon. L. Paige Marvel, US Tax Court
Kathleen Pakenham, Cooley LLP

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Robert S. Fink Moderates A Panel Entitled “The Attorney-Client Privilege and Work Product Protection in Tax Cases – Developments and Best Practices" At The ABA's 38th Annual Criminal Tax Fraud Institute And 11th Annual Civil Tax Controversy Institute
2021-12-10 08:30 - 09:30
On December 10, 2021, Robert S. Fink moderates a panel entitled “The Attorney-Client Privilege and Work Product Protection in Tax Cases – Developments and Best Practices” at the ABA’s 38th Annual Criminal Tax Fraud Institute and 11th Annual Civil Tax Controversy Institute.
Description: December 5, 2021 marked the sixty-year anniversary of the decision in Kovel v. United States, a landmark holding that continues to shape tax controversy practice. The Kovel decision, and the broader principles of the attorney-client privilege and work product immunity embody our ethical obligations to keep client communications confidential. This panel will discuss recent developments that you need to know to meet these obligations in the context of domestic and cross-border tax investigations.
Moderator:

Robert S. Fink, Kostelanetz & Fink, LLP

Speakers:

Ajay Gupta, Moore Tax Law Group LLC
Brian C. McManus, Latham & Watkins LLP
Guinevere Moore, Moore Tax Law Group LLC
Bruce Zagaris, Berliner Corcoran & Rowe LLP
Zhanna Zierling, Moore Tax Law Group LLC

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The Law Firm Antiracism Alliance Hosts Third Discussion In Series Entitled “Diversity in the Tax Bar” As Part Of Its Tax System Working Group Discussion Series
2022-01-07 13:30 - 15:00

Don Fort Participates In A Panel Entitled "Cryptocurrency Update" With The FBA Section On Taxation
2022-01-11 12:00 - 13:00
On January 11, 2022, Don Fort participates in a panel entitled “Cryptocurrency Update” with the Federal Bar Association Section on Taxation.
Description: Speakers from the IRS, Eversheds Sutherland, and Kostelanetz & Fink discuss current cases and developments in the field, technology tools and audit streams, the recent John Doe summonses, and Operation Hidden Treasure. Topics also include important changes to the Infrastructure Investment and Jobs Act, as well as IRS guidance on hard forks and like-kind exchanges.
After attending this program, participants will be able to:

Understand new developments related to cryptocurrency
Analyze the potential impact of cryptocurrency information reporting requirements in the Infrastructure Investment and Jobs Act
Assist tax practitioners by describing cryptocurrency enforcement efforts and guidance by the IRS

Panelists:

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

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Caroline D. Ciraolo Participates In A Panel Entitled “Tax Fraud Trends" At The ABA/ABA Financial Crimes Enforcement Conference
2022-01-12 13:45 - 14:30
On January 12, 2022, Caroline D. Ciraolo participates in a panel entitled “Tax Fraud Trends” at the ABA/ABA Financial Crimes Enforcement Conference.
Description: The Pandora Papers shined a light on potential tax fraud schemes that touch U.S. financial institutions. Even in the midst of the pandemic, the IRS issued their annual report in November 2020 on criminal enforcement of tax fraud where they stated they launched 1,600 investigations and identified $2.3 billion in tax fraud schemes. Join us as we check in with experts in tax fraud to discuss recent trends and what you can do to fine-tune your surveillance to identify tax-related fraud risks.
Speakers:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP
Stephanie Brooker, Partner, Gibson Dunn & Crutcher LLP

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Caroline D. Ciraolo Participates In A Panel Entitled "In The Eye of the Beholder: When Does a Civil Tax Case Move to a Criminal Tax Investigation?" At The 40th Annual Florida Bar Tax Section International Tax Conference
2022-01-14 11:20 - 12:10
On January 14, 2022, Caroline D. Ciraolo participates in a panel entitled “In The Eye of the Beholder: When Does a Civil Tax Case Move to a Criminal Tax Investigation?” at the 40th Annual Florida Bar Tax Section International Tax Conference.
Description: The IRS puts the current gross tax gap at more than $1 trillion. The gap consists of underreporting, underpayment, and non-filing, and each of these areas includes potential criminal targets. So what moves tax noncompliance from the civil to the criminal realm? This panel will address the IRS focus on civil fraud enforcement and criminal referrals. Topics will include the creation, organization, and initiatives of the IRS Office of Fraud Enforcement, current IRS enforcement priorities, recent criminal tax prosecutions, and more.
Speakers:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP, Washington DC
Jeffrey Neiman, Partner, Marcus Neiman Rashbaum & Pineiro, LLP, Ft. Lauderdale, FL

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Caroline D. Ciraolo Participates In The "Audits and Tax Controversy Panel" For The Florida Tax Institute
2022-02-03 10:00 - 11:30
On February 3, 2022, Caroline D. Ciraolo participates in the “Audits and Tax Controversy Panel” for the Florida Tax Institute.
Description: The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions. The reviews are expected to include the individual tax return of the sophisticated taxpayer as well as related partnerships, foundations, trusts, retirement plans, and other business structures. In the past year, the IRS also reaffirmed its interest in cross border activities with the announcement of three new campaigns targeting Nonresident Aliens who receive rental income from U.S. real property; FIRPTA compliance in connection with the withholding of tax and reporting obligations on the disposition of U.S. real property interests; and the U.S. activities of financial service entities and whether foreign investors participating in “inbound” lending transactions were engaged in a U.S. trade or business and generated income effectively connected with a U.S.-situs lending trade or business. The panel discusses these and other current developments and their implications for high wealth foreign and domestic taxpayers.
Speakers:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP, Washington DC
Carol Madison, IRS
Fred Murray [Moderator], IRS
Deborah Palacheck, IRS
Clifford Scherwinski, IRS
Steven Toscher, Hochman Salkin Toscher Perez P.C.

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The Law Firm Antiracism Alliance Hosts Fourth Discussion In Series Entitled “Diversity in the Tax Bar” As Part Of Its Tax System Working Group Discussion Series
2022-02-11 14:00 - 15:30
Description: The LFAA Tax System Working Group, in conjunction with the American College of Tax Counsel, the American Tax Policy Institute and the Tax Section of the American Bar Association, is organizing a ten-part discussion series on diversity in the tax bar. Over the course of this series of virtual discussions, participants learn about the current state of diversity in the tax bar, opportunities for diverse tax attorneys in different practice settings, and steps that the tax bar should be taking to create sustainable diversity, equity and inclusion strategies.
The fourth discussion in the series, on Feb. 11, 2022, addresses the academic perspective on recruiting and retaining diverse tax lawyers.
Panelists:

Alice G. Abreu, Temple University Beasley School of Law
Steven Dean, Brooklyn Law School
Samuel C. Thompson, Jr., Penn State Law

Moderator:

Sabrina Conyers, McGuire Woods LLP

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Caroline D. Ciraolo Moderates A Panel Entitled "In The Eye of the Beholder: What Moves a Tax Case from Civil to Criminal?" At The ABA White Collar Crime Conference
2022-03-02 10:30 - 11:45
On March 2, 2022, Caroline D. Ciraolo moderates a panel entitled “In The Eye of the Beholder: What Moves a Tax Case from Civil to Criminal?” at the 2022 ABA White Collar Crime Conference.
Description:
The IRS puts the current gross tax gap at more than $1 trillion dollars. The gap consists of underreporting, underpayment, and non-filing, and each of these areas includes potential criminal targets. So what moves tax noncompliance from the civil to the criminal realm? This panel addresses the IRS focus on civil fraud enforcement and criminal referrals, including the creation, organization, and initiatives of the IRS Office of Fraud Enforcement, current IRS enforcement priorities, recent criminal tax prosecutions, what happens when a criminal tax investigation is discontinued or declined, and more.
Moderator:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP (Washington, D.C.)

Panelists:

Sandra Brown, Partner, Hochman Salkin Toscher & Perez (Beverly Hills, CA)
Kathy Keneally, Partner, Jones Day (New York, NY)
Caryn Finley, AUSA, U.S. Attorney’s Office, Western District of North Carolina (Charlotte, NC)
Damon Rowe, Director, IRS Fraud Enforcement Office

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Robert M. Russell Moderates A Panel Entitled “Cryptocurrency and Blockchain Technologies: An Industry Perspective” At The FBA's 2022 Tax Law Conference
2022-03-03 11:30 - 12:30
On March 3, 2022, Robert M. Russell moderates a panel entitled “Cryptocurrency and Blockchain Technologies: An Industry Perspective” at the Federal Bar Association’s 2022 Tax Law Conference.
Description: The incorporation of rapidly evolving cryptocurrency and blockchain technologies into the mainstream economy has undergone a substantial recent acceleration. Consistent with that trend, the infrastructure bill passed into law last year added a definition of “digital assets” to the Internal Revenue Code and expanded information reporting for transactions in cryptocurrency is on the horizon. Meanwhile, compliance challenges remain a focus of significant attention for industry, taxpayers and the government with a number of regulatory agencies working to apply existing legal frameworks to these emerging technologies. This panel provides a roundtable, industry-focused discussion of the broad range of tax and other regulatory issues raised by transactions in cryptocurrency.
Learning Objectives:

Understand how blockchain technologies are playing an increasingly important role in the mainstream economy.
Identify challenges in applying existing tax and other regulatory regimes to transactions in cryptocurrency.
Evaluate legislative and regulatory approaches to addressing compliance challenges presented by transactions in cryptocurrency.

Moderator:

Robert M. Russell, Counsel, Kostelanetz & Fink, LLP

Panelists:

Liz Chien, Head of Global Tax, Protocol Labs
Michelle Gitlitz, General Counsel, Flexa Network Inc.
Ari Redbord, Head of Legal and Government Affairs, TRM Labs
Jamison Sites, Blockchain/Digital Assets Tax Lead, RSM US LLP

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Robert M. Russell Participates In a Panel Entitled “Tax Practice in a Perfect Storm - Assessing the Impacts of Inflation, Supply Chain Disruption, and Legislative Uncertainty on the Tax Function” At The Tax Executives Institute's Midyear Conference
2022-03-21 09:45 - 10:45
On March 21, 2022, Robert M. Russell participates in a panel entitled “Tax Practice in a Perfect Storm – Assessing the Impacts of Inflation, Supply Chain Disruption, and Legislative Uncertainty on the Tax Function” at the Tax Executives Institute’s 2022 Midyear Conference.
Description: The tax function is in the midst of uncertainty on all fronts ranging from economic recovery to regulatory guidance to domestic and foreign political uncertainty. In this course, we explore how tax departments are responding to the potential for double taxation as a result of the recently issued foreign tax credit regulations and OECD guidance and the impact, if any, ESG has on their reaction.
Moderator:

Kevin M. Jacobs, Managing Director, Alvarez & Marsal Taxand, LLC

Panelists:

Robert M. Russell, Counsel, Kostelanetz & Fink, LLP
Alexandra Minkovich, Partner, Baker McKenzie
George L. Salis, Principal Economist and Tax Policy Advisor

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Caroline D. Ciraolo Moderates A Panel Entitled "Blurred Lines—The Edge of Civil and Criminal Tax Enforcement" For The Virtual 22nd Annual U.S. And Europe Tax Practice Trends Conference
2022-03-31 10:45 - 12:00
On March 31, 2022, Caroline D. Ciraolo moderates a panel entitled “Blurred Lines—The Edge of Civil and Criminal Tax Enforcement” for the Virtual 22nd Annual U.S. and Europe Tax Practice Trends Conference.
Description:
With the increased focus on shrinking the tax gap and combatting abusive tax transactions, the line between tax avoidance and tax evasion continues to fade. When does strategic tax planning cross the line into intentional violations of known legal duties? Does it really come down to lying, cheating, and stealing? Panelists from England, Germany, France, Italy, and the United States discuss current civil and criminal tax enforcement priorities, including COVID stimulus schemes, cum ex transactions, and wilful attempts to hide permanent establishments, the impact of whistleblowers, and recent criminal investigations and prosecutions. CLE credits are offered for this event.
Moderator:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP (Washington, D.C.)

Panelists:

Jeffrey A. Neiman, Partner, Marcus Neiman Rashbaum & Pineiro LLP
Raul-Angelo Papotti, Chiomenti
Alice Rousseau – Alice Rousseau Avocats
Polly Sprenger, Partner, Global Investigations, Addleshaw Goddard LLP
Sabine Stetter, Managing Partner, Stetter Attorneys at Law

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Caroline D. Ciraolo Participates In A Panel Entitled "Pathways to Careers in Tax Law (Tax Controversy)" With The ABA Tax Section
2022-04-11 13:00 - 14:00
On April 11, 2022, Caroline D. Ciraolo participates in a panel entitled “Pathways to Careers in Tax Law (Tax Controversy)” with the Tax Section of the American Bar Association (ABA).
Description:
Caroline Ciraolo of Kostelanetz & Fink and Scott Michel of Caplin & Drysdale discuss careers in the tax controversy field, focusing on career development at varying stages of one’s career. Looking through the lens of a lawyer making her way through a tax controversy practice at a law firm, from her first days on the job all the way through attaining more senior status, they talk about topics such as successful career strategies they have observed, the choices faced by practitioners throughout their career, the importance of having and being a good mentor, the role of organizations such as the Tax Section in career development, varying approaches to marketing, and leadership on diversity, equity and inclusion issues.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP (Washington, D.C.)
Scott Michel, Member, Caplin & Drysdale (Washington, D.C.)

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Kostelanetz & Fink Sponsors And Don Fort Participates In The 2022 AML Partnership Forum
2022-04-20 - 2022-04-22
On April 20 & 22, 2022, Don Fort moderates a keynote address by IRS-CI Chief Jim Lee and participates in a separate panel entitled “Views from Law Enforcement (FBI, IRS, DHS)” for the 2022 AML Partnership Forum. Kostelanetz & Fink, LLP is an event sponsor along with Condor Consulting, Truist, Ally, Allen & Overy, and AML RightSource.
The AML Partnership Forum features experts from both private and public sectors and provides an opportunity for members of the AML community from financial service providers and law enforcement agencies to have candid, confidential conversations on key topics on preventing money laundering, terrorist financing and other financial crimes.
Click here for more information and to register.
