Making Tax Policy In An Era Of Artifical Intelligence - Can It Survive The Robots?
2024-06-20 13:00 - 14:30 (America/New_York)
Macdonald “Mac” Norman will participate in a panel titled “Making Tax Policy in an Era of Artificial Intelligence – Can It Survive the Robots?” presented as part of the American Bar Association’s CLE Programming.
Description: While AI is frequently discussed in terms of disruption to private sector activities, its impact on government services has made fewer headlines. But AI may have significant repercussions for policymaking, including for tax. This panel will tackle the challenges confronting tax policymakers as a result of AI-influenced comment letters, industry lobbying, and disinformation campaigns, and whether current policymaking rules remain fit for purpose in such an environment.
Moderator:

Jeremiah Coder, Revenue Jersey

Panelists:

Macdonald “Mac” Norman, Kostelanetz LLP
Adrienne Griffin, Branch Chief, Procedure & Administration Branch 2, IRS Chief Counsel
Alexandra Minkovich, Baker McKenzie
Varun Jain, Senior Counselor, OIRA, Office of Management and Budget

For full event details and registration, click here.
CLE Credit is available for this event.

International Taxation In Cross-Border Operations
2024-07-03 | University of San Diego
Caroline D. Ciraolo is a guest instructor, joined by Leo Unzeitig of Chamberlain Hrdlicka, for the University of San Diego (USD) School of Law and Instituto Tecnológico Autónomo de México (ITAM). Taught concurrently in English and Spanish, this virtual and in-person hybrid, 8-month program aims to provide participants with solid and specialized training in international tax matters from the perspective of the United States and Mexico. It will address the international tax consequences of cross-border operations and investments in the contexts of tax, estate planning and litigation through the analysis of practical cases.
The program is intended for lawyers, accountants and professionals from Mexico and the United States who seek to delve deeper into the complexity of the tax systems of both countries by integrating a binational approach into their respective practices. In-person classes will be held at the ITAM in Mexico City.
For full program details and registration information, please click here.

Resolving a Criminal Tax Matter, Criminal Investigations, Plea Deals, & Sentencing
2024-07-19 16:00 - 17:30 (America/New_York) | University of San Diego
Caroline D. Ciraolo will speak on a panel at the 9th Annual University of San Diego School of Law’s RJS LAW Tax Institute on “Resolving a Criminal Tax Matter, Criminal Investigations, Plea Deals, & Sentencing” on Friday, July 19, 2024.
Description: Caroline Ciraolo is joined by Charles P. Rettig, Partner, Chamberlain Hrdlicka and 49th Commissioner of the IRS, the Honorable Larry Alan Burns, Senior Judge, U.S. District Court, Southern District of California, Sandra R. Brown, Partner, Hochman Salkin Toscher Perez, PC and former Acting U.S. Attorney, Central District of California, to discuss criminal tax investigations and prosecutions, including current IRS enforcement priorities, the roles of IRS Criminal Investigation, DOJ Tax Division, the district courts, and the U.S. Sentencing Guidelines, and the future of IRS enforcement efforts.
For full program details and registration information, please click here.

I Always Think That Everything Could Be A Trap: Ethical Dilemmas in Tax Controversy (CLE)
2024-08-13 13:00 - 14:30 (America/New_York)
Megan L. Brackney will participate in an online American Bar Association panel titled “I Always Think That Everything Could Be A Trap: Ethical Dilemmas in Tax Controversy” on Tuesday, August 13, 2024 at 1pm EDT.
Description: As a tax controversy attorney, you never know what a client might ask, do, or say. A simple audit could soon become a complex web of issues, conflicting interests, and legal dilemmas. This program will discuss scenarios tax controversy attorneys face, address different ethical rules that apply, and dive into some of the true gray areas of a tax controversy practice.
Panelists:

Megan L. Brackney, Kostelanetz LLP
Zhanna A. Ziering, Moore Tax Law Group LLC
Aaron M. Esman, Moore Tax Law Group LLC

For full program details and registration information, please click here.
1.5 hours of CLE Ethics credit are available for this event.

Bringing Your Client Into Compliance Without Coloring Outside The Lines
2024-09-10 13:45 - 14:45 (America/New_York)
Caroline D. Ciraolo will moderate a panel titled “Bringing your client into compliance without coloring outside the lines” as part of the 5th Annual International Tax Conference hosted by the International Fiscal Association (IFA). The conference will take place virtually on September 10 & 11.
Description: Your client failed to report interests in or control over foreign financial accounts, foreign entities, foreign trusts, or gifts from foreign individuals. You know there are several paths to compliance, some much more favorable than others, and your client insists on the broadest protection at the lowest possible cost. This all-to-common scenario presents thorny ethical dilemmas for tax professionals. This panel will walk through the lifecycle of bringing a client with international tax issues into compliance, the ethical issues tax professionals face along the way, the current, relevant authority and guidance, and best practices.
Moderator:

Caroline D. Ciraolo, Kostelanetz LLP, Washington, D.C.

Panelists:

Christopher Rizek, Holland & Knight, Washington, DC
Guinevere Moore, Moore Tax Law, Chicago, IL
Rochelle Hodes, Crowe, Washington, DC

For full program details and registration information, please click here.

Top 10 Federal Tax Issues
2024-10-05 10:15 - 11:30 (America/Los_Angeles)
On October 5, 2024, Megan L. Brackney will participate in a panel titled “Top 10 Federal Tax Issues” as part of the National Association of State Bar Tax Sections’ 45th Annual Conference in Boston, MA. This in-person event will feature speakers and recognized leaders in the estate planning, federal, state and local tax fields and provide attendees with opportunities to learn about and discuss current tax issues.
Panel Description:
This session will discuss current developments and hot topics in federal tax practice, focusing on the recent U.S. Supreme Court decisions in Moore v. United States and Loper Bright Enterprises v. Raimondo and their practical impact on taxpayers, as well as recent federal appeals court decisions including cases related to Tax Court jurisdiction and state law limited partners and self-employment tax. We will also discuss current developments related to IRS enforcement priorities, including private placement life insurance and international information return penalties.
Moderator:

Jaye Calhoun, Kean Miller, New Orleans, LA

Panelists:

Megan L. Brackney, Kostelanetz LLP, New York, NY
John A. Karasek, McDermott Will & Emery, Boston, MA
Brock E. Whalen, Holland & Knight, Austin, TX

For full program details and registration information, please click here.

Ethical Considerations in Jury Selection
2024-10-16 13:45 - 14:45 (America/Los_Angeles)
Kostelanetz LLP partner Sharon McCarthy spoke at the Trial By Jury 2024 program, hosted by the Practicing Law Institute (PLI) on October 16, 2024, in New York City. The panel, “Ethical Considerations in Jury Selection,” addressed the ethical challenges of using jury consultants and investigating jurors through social media. The panel explored how to avoid ethical pitfalls during voir dire and the extent to which a juror’s online presence should factor into their suitability.
Trial By Jury was a one-day program designed for both new trial attorneys and seasoned litigators. It featured sessions taught by prominent federal and state judges, as well as leading litigators from top law firms across the United States. Attendees refined their skills in jury selection, cross-examination, opening and closing statements, and managing ethical issues that arise during jury trials.
Other participants on the panel included the Hon. Stewart D. Aaron of the United States District Court, Southern District of New York; Anirudh Bansal of Cahill Gordon & Reindel LLP; and the Hon. Margaret M. Garnett of the United States District Court, Southern District of New York.
You can learn more here.
Sharon McCarthy is a Fellow of the American College of Trial Lawyers and an award-winning litigator with extensive public service experience, including her tenure as an Assistant US District Attorney in the Southern District of New York. Twice a recipient of the Director’s Award for Superior Performance, Sharon has prosecuted cases in the Violent Crimes and Public Corruption units. Her practice areas include tax fraud, securities fraud, and insider trading, and she also conducts internal investigations for corporate and institutional clients. Sharon serves as an adjunct professor at Fordham Law School, teaching trial advocacy, and has been recognized by New York Super Lawyers and Best Lawyers in America for her work in white-collar criminal defense.

'IRS Enforcement Efforts and the Path Ahead From the Experts'
2024-10-20 13:15 - 15:45 (America/Los_Angeles)
Kostelanetz LLP partner Megan L. Brackney spoke on two panels at the 83rd NYU School of Professional Studies Institute on Federal Taxation, a six-day program dedicated to high-level discussions on federal tax matters, tax code updates, and key developments in tax administration. Megan’s panels focused on IRS enforcement and professional ethics in tax practice, two critical areas for tax professionals.
Her first panel, “IRS Enforcement Efforts and the Path Ahead,” took place on Thursday, October 20 from 1:15 to 2:45 PM. This session will feature the IRS’s former Commissioner, IRS Chief Counsel, and Counselor to the IRS Commissioner, providing valuable context and insights into the IRS’s long-term strategy, which includes its Congressional mandate and $60 billion in supplemental funding to enhance enforcement efforts. The panel will focus on enforcement priorities related to digital assets, large corporations, large partnerships, and high-net-worth individuals, offering a forward-looking view of what tax professionals should expect as the IRS implements new programs aimed at these groups.
Megan also joined the “From the Experts: Professional Responsibility Issues in Your Tax Practice” panel from 2:45 to 3:45 PM. This session covered the ethical and professional challenges tax practitioners face when representing clients in disputes with the IRS. With real-world, practical advice from seasoned professionals, this panel discussed various factual scenarios to help practitioners navigate tricky ethical dilemmas and ensure they protect both themselves and their clients.
The NYU Institute on Federal Taxation takes place at The Westin New York at Times Square from October 20-25, 2024. It offered continuing education credit to attendees, and Kostelanetz LLP is a Silver sponsor of the event.
Event details are available here.
Partner Megan L. Brackney is an experienced tax attorney, Chair-Elect of the American Bar Association Section of Taxation, and an adjunct professor at New York University School of Law. Megan is also former Assistant U.S. Attorney for the Southern District of New York and a frequent speaker and contributor at local and national conferences on taxation, ethics in tax practice, penalties, and tax controversy.

Tax Penalties after the Revolution of Summer ’24 for the Tax Section of the Florida Bar
2024-10-23 12:00 - 13:00 (America/New_York)
Kostelanetz counsel Gray Proctor presented a virtual CLE session through the Florida Bar, “Tax Penalties after the Revolution of Summer ’24”.
The session covered how IRS penalties in future tax controversy and criminal tax fraud cases may be affected by the outcome of SEC v. Jarkesy, a Supreme Court case decided in June 2024 that found that the Seventh Amendment entitles a defendant to a jury trial when the Securities and Exchange Commission seeks civil penalties for securities fraud.
The Jarkesy decision is apt to be tested in the coming months and years, because the Supreme Court’s opinion arguably applies to “punitive” civil penalties imposed by other administrative agencies, including the IRS. Gray discussed potential federal policy responses that could result from the case if courts begin to find that taxpayers now have the right to a jury trial in federal district courts where tax penalties are contested.
The session was held on October 23, 2024, via Zoom, offering one hour of CLE credit for free to members of the tax section of the Florida Bar. You can learn more about this session and watch the recording here.
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal penalties. He also maintains a trial support practice focusing on dispositive motions and other key issues upon which an appeal might follow.

40th Annual UCLA Tax Controversy Conference
2024-10-24 08:30 - 18:00 (America/New_York)
Kostelanetz LLP partner Caroline Ciraolo will participate in a panel discussion during UCLA’s 40th Annual Tax Controversy Conference on October 24, 2024, at the Beverly Hills Hotel in Beverly Hills, California. Caroline will speak on, “The Investigation, Assertion, and Defense of Civil Fraud Penalties” from 11:10 am – 12 pm.
Kostelanetz LLP is a proud sponsor of the 40th Annual UCLA Extension’s Annual Tax Controversy Conference, the preeminent conference exclusively dedicated to tax controversy and tax litigation. This event provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience. It is ideal for tax attorneys, accountants, CPAs, enrolled agents, financial advisors, and other tax professionals. Accounting, tax, and law students are also encouraged to attend.
You can learn more about the event and register here.
Caroline Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Let’s Come to An Agreement – The Benefits and Pitfalls of Alternative Dispute Resolution of Tax Controversies
2024-10-24 14:10 - 15:10 (America/New_York)
Kostelanetz LLP counsel Dan Rosen will participate in a panel discussion during UCLA’s 40th Annual Tax Controversy Conference on October 24, 2024, at the Beverly Hills Hotel. Dan will speak on, “Let’s Come to An Agreement – The Benefits and Pitfalls of Alternative Dispute Resolution of Tax Controversies” from 2:10 pm – 3:10 pm.
Kostelanetz LLP is a proud sponsor of the 40th Annual UCLA Extension’s Annual Tax Controversy Conference, the preeminent conference exclusively dedicated to tax controversy and tax litigation. This event provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience. It is ideal for tax attorneys, accountants, CPAs, enrolled agents, financial advisors, and other tax professionals. Accounting, tax, and law students are also encouraged to attend.
You can learn more about the event and register here.
Daniel Rosen is of Counsel at Kostelanetz LLP. He is a veteran trial lawyer with over 24 years of experience in private practice and with the IRS Office of Chief Counsel

Superman’s Krypto – The IRS’s Focus on Civil and Criminal Enforcement of Cryptocurrency
2024-10-24 16:45 - 17:50 (America/New_York)
Kostelanetz LLP partner Jay Nanavati will participate in a panel discussion during UCLA’s 40th Annual Tax Controversy Conference on October 24, 2024, at the Beverly Hills Hotel. Jay will speak on, “Superman’s Krypto – The IRS’s Focus on Civil and Criminal Enforcement of Cryptocurrency” from 4:45 pm – 5:50 pm.
Kostelanetz LLP is a proud sponsor of the 40th Annual UCLA Extension’s Annual Tax Controversy Conference, the preeminent conference exclusively dedicated to tax controversy and tax litigation. This event provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience. It is ideal for tax attorneys, accountants, CPAs, enrolled agents, financial advisors, and other tax professionals. Accounting, tax, and law students are also encouraged to attend.
You can learn more about the event and register here.
Jay Nanavati is a criminal tax defense attorney and a fellow of both the American College of Trial Lawyers and the American College of Tax Counsel. According to Chambers USA, which has ranked him nationally for the last seven years, Jay “is held in high regard for his strength in handling criminal tax matters . . .He is an excellent trial attorney, he’s very sophisticated. His judgment is excellent.”

83rd Annual NYU Institute on Federal Taxation - The Tax Advisor as Provider of Tax Insurance and Penalty Protection: Ethical Guardrails and Limits and Malpractice Risks
2024-10-24 17:15 - 18:55 (America/New_York)
Kostelanetz LLP partner Bryan C. Skarlatos will speak on a key panel at the 83rd Institute on Federal Taxation, hosted by the NYU School of Professional Studies (SPS) from October 20-25, 2024, at The Westin New York at Times Square. Bryan will present on “The Tax Advisor as Provider of Tax Insurance and Penalty Protection: Ethical Guardrails and Limits and Malpractice Risks,” a session examining the role of tax advisors in providing guidance that can serve as insurance to help abate IRS penalties. The panel will explore ethical standards, limitations of tax opinions, and third-party tax insurance, taking place on Thursday, October 24th, from 5:15-6:55 PM.
Now in its 83rd year, the Institute focuses on high-level tax matters, including updates in tax administration, recent tax code changes, and expert analysis of topics such as trust and estate matters, tax controversy, executive compensation, and international taxation. Attendees will gain insights from practitioners and educators that could help them save their clients’ tax dollars and provide outstanding service.
Continuing education credit is available to attendees, and Kostelanetz LLP is a Silver sponsor of the event, with Bryan serving on the advisory board.
The Institute draws tax professionals from across the country, including attorneys, accountants, financial planners, and tax law specialists, making it one of the premier gatherings for federal tax expertise.
You can learn more about the event and register here.
Bryan C. Skarlatos is a tax controversy attorney with over 30 years of experience. He has been recognized by Super Lawyers as one of New York’s Top 100 lawyers and was named “Lawyer of the Year” for New York tax litigation for 2025. In addition to serving on the advisory board of NYU’s Institute on Federal Taxation, Bryan is an adjunct professor at NYU School of Law. He also founded the annual New York University Tax Controversy Forum. He is frequently retained by individual and corporate clients, as well as foreign and state governments, to provide expert testimony on tax penalties.

IRS International Information Reporting Penalties – Current Updates and Avoiding Malpractice Claims
2024-10-31 10:30 - 11:30 (America/Los_Angeles)
Kostelanetz LLP partner Michael Sardar will be featured at the 2024 Procopio International Tax Institute (PITI) conference, which will take place from October 30 to November 1, 2024, at the Intercontinental Hotel in San Diego, CA. As part of a breakout session, “IRS International Information Reporting Penalties: Current Updates and Avoiding Malpractice Claims,” Michael will speak alongside IRS attorney advisor Lara A. Banjanin on October 31 from 10:30-11:30 AM PT. The session will also include Eric D. Swenson, partner at Procopio, and Daniel N. Price, founder of the Law Office of Daniel N. Price.
The three-day PITI conference, affiliated with Georgetown Law’s graduate tax program, is dedicated to cross-border tax issues and international tax compliance between the US and Mexico. It is designed for tax law practitioners, corporate tax departments, financial managers, government officials, and attorneys practicing in the US and Mexico. Attendees will learn about US-Mexico tax relations, M&A from a US-Mexico perspective, navigating trusts and estates in Mexico, and resolving international tax controversies.
Discounts are available for students, professors, and government employees.
International tax compliance can be difficult for clients to navigate, as regulations are often unclear and may not align with the realities of international transactions. PITI 2024 provides a unique opportunity to explore the complexities of US-Mexico tax relations and understand the far-reaching impacts of cross-border transactions. Sardar’s session will focus on contemporary issues surrounding foreign reporting obligations, upcoming changes expected in 2025, and strategies to best prepare clients for tax compliance measures.
Learn more about PITI 2024 and register here.
Michael Sardar is an experienced tax attorney and co-chair of the Federal Bar Association’s section on taxation’s New York chapter. Michael has vast experience in IRS foreign bank and asset reporting (FBAR) requirements and the IRS Offshore Voluntary Disclosure Program. He represents a variety of clients in civil and criminal tax investigations and prosecutions, as well as other white-collar criminal matters in New York State and New York City.

Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know (CLE)
2024-11-01 13:15 - 14:15 (America/New_York)
On November 1, 2024, Bryan C. Skarlatos will co-moderate a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” as part of the Practising Law Institute’s “Tax Strategies 2024 – New York City” programming. Attendees will receive the latest information, strategies, and practical insights available from leading tax practitioners across the United States, along with policymakers from the IRS and the Department of the Treasury.
Course Description:
This panel will focus on the various judicial doctrines and ethical issues that arise in the corporate tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on corporate transactions, including 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.
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions.
Respond to the IRS in an audit.

Moderators:

Bryan C. Skarlatos, Kostelanetz LLP, New York City
S. Starling Marshall, Crowell & Moring, New York City

For full program details and registration information, please click here.
CLE credit is available for this event.

Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2024 New York City
2024-11-01 13:15 - 14:15 (America/New_York)
Kostelanetz LLP partner Bryan C. Skarlatos will speak at the Practicing Law Institute’s (PLI) three-day program, Tax Strategies 2024, which focuses on complex corporate tax issues and transactions. Bryan will participate in a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” with S. Starling Marshall on Friday, November 1 at 1:15 PM EST. This session will cover the ethical challenges that corporate tax advisors face during the tax planning process, discussing critical judicial doctrines and standards such as Circular 230, AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct. Attendees will gain insights into how to navigate ethical pitfalls and avoid malpractice while providing tax opinions to corporate clients.
Tax Strategies 2024 is designed for tax professionals specializing in corporate transactions, including M&A, reorganizations, joint ventures, and cross-border activity. The conference will take place in New York City from October 30 to November 1, 2024, with additional sessions scheduled for Chicago and Los Angeles later in the year. The event includes in-depth discussions on the tax impacts of corporate transactions, tax controversy issues, and the role of financial instruments in litigation. Virtual participation options are available for both the New York and Chicago programs.
You can learn more about Tax Strategies 2024 and register here.
Bryan C. Skarlatos is a tax controversy attorney with over 30 years of experience. He has been recognized by Super Lawyers as one of New York’s Top 100 lawyers and was named “Lawyer of the Year” for New York tax litigation for 2025. In addition to serving on the advisory board of NYU’s Institute on Federal Taxation, Bryan is an adjunct professor at NYU School of Law. He also founded the annual New York University Tax Controversy Forum. He is frequently retained by individual and corporate clients, as well as foreign and state governments, to provide expert testimony on tax penalties.

2024 Hawaii Tax Institute
2024-11-03 - 2024-11-07
Kostelanetz partner Caroline Ciraolo and Director of Investigations Don Fort participated in multiple panels at the 61st annual Hawaii Tax Institute, the largest tax and wealth transfer conference in the U.S. that takes place in Waikiki Beach in Honolulu.
The comprehensive five-day conference covers several aspects of wealth transfers, tax administration, estate and tax planning, and tax controversy as they pertain to high-net-worth individuals. You can learn more about the Hawaii Tax Institute here.
Caroline and/or Don participated in the following:
Monday, November 4, 1:30 PM – 2:15 PM: “Is the Tide Turning? Current Developments Regarding International Information Return Penalties and Ethical Considerations”
Caroline spoke on this panel covering recent developments in the international tax space concerning the often onerous civil penalties taxpayers face for failure to report their interests in certain foreign entities, assets, accounts, and transactions.
Tuesday, November 5, 6:30 AM – 7:45 AM: “Early Bird Bonus Session: Tax Treaties for the Wealth Transfer Professional”
Caroline spoke at this early morning panel covering the complex and often misunderstood areas of wealth transfer tax planning, reporting obligations, and tax enforcement that apply to foreign and dual residents who may be eligible for reduced tax rates or tax avoidance under tax treaties.
Tuesday, November 5, 11:00 AM – 11:45 AM: “How the IRS Is Changing and What to Expect in the Future”
Caroline moderated this panel, and Don joined other former and current IRS leaders to speak on the technological, personnel, and administrative changes that have occurred and are anticipated under the Inflation Reduction Act.
Wednesday, November 6, 2:30 PM – 3:20 PM: “Conducting Financial Investigations from Both Sides of the Aisle”
Don spoke on this panel alongside other former and current IRS leaders on both the defense and prosecution perspectives of criminal tax investigations and prosecutions. The panel
included a deep dive into methodologies, strategies, and techniques in complex financial investigations, ethical issues, and legal frameworks involved.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, serving as a neutral in alternative dispute resolutions, providing expert consultations and testimony, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions.
Don is the Director of Investigations at Kostelanetz LLP and the former Chief of the Internal Revenue Service’s Criminal Investigation Division. Having spent nearly 30 years in law enforcement for the federal government, Don has deep expertise in financial crimes and has an extensive network of connections both within the government and in private industry.

Tax Enforcement Trends: What’s Hot and What’s Not
2024-11-08 10:15 - 11:05 (America/New_York) | Mohegan Sun Resort & Casino, 1 Mohegan Sun Blvd., Uncasville, CT, 06382, United States
Kostelanetz partner Christopher Ferguson will speak at the IRS Representation Conference on November 8, 2024. He is a panelist for the session “Enforcement Trends: What’s Hot and What’s Not” that will be held from 10:15 AM to 11:05 AM Eastern.
The panel will cover a variety of tax enforcement topics, such as the IRS’s efforts with respect to the Employee Retention Credit, cryptocurrency, payroll tax debt, high net worth non-filers, and other hot issues. The panel will also cover what practitioners can expect in examinations, collections, and criminal tax investigations in 2025.
The New England IRS Representation Conference will be held November 7-8, 2024, at the Mohegan Sun Resort and Casino in Uncasville, CT. Ten hours of continuing education credit, including one hour of ethics, can be earned by attending the event. Virtual attendance options are available. You can learn more about the conference here.
Chris has over two decades of experience as a litigator, concentrating his practice on white-collar criminal defense as well as civil tax controversies, criminal tax fraud, and other regulatory enforcement matters. Chris also has extensive experience handling complex civil litigation and internal investigations.
CLE credit is available for this event.

The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil
2024-11-12 13:50 - 15:30 (America/Los_Angeles)
Kostelanetz LLP partner Michael Sardar will lead a session at the 2024 Taxpayer Representation Super Conference, hosted by the American Society of Tax Problem Solvers (ASTPS), from November 12-14, 2024, at Embassy Suites San Antonio Riverwalk. Michael’s session, “The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil,” on November 12 from 1:50 pm to 3:30 pm will focus on managing risk in large and complex IRS audits, where large adjustments are likely. He will guide attendees through strategies for preserving clients’ privileges during sensitive audits, recognizing signs that an audit could escalate to a criminal investigation and ensuring clients remain compliant with their tax reporting obligations.
The Super Conference, a three-day event dedicated to representing clients before the IRS, features 15 sessions on high-level tax resolution topics. Attendees, including practitioners who focus on criminal and civil tax matters, white-collar criminal defense and government investigations, and tax controversy, will learn about issues ranging from criminal tax investigations to tax controversy litigation.
As IRS enforcement is expected to increase in 2025, the conference provides timely insights. Other notable sessions include how to file a protest letter to appeal denied Offers in Compromise, the IRS’s use of AI in auditing high-income taxpayers, and strategies for handling cases led by newly hired IRS agents.
You can learn more about the ASTPS Super Conference and register here. While live attendance in San Antonio is currently waitlisted, virtual attendance options are still available.
Michael Sardar is an experienced tax attorney and co-chair of the Federal Bar Association’s section on taxation’s New York chapter. Michael has vast experience in IRS foreign bank and asset reporting (FBAR) requirements and the IRS Offshore Voluntary Disclosure Program. He represents a variety of clients in civil and criminal tax investigations and prosecutions and other white-collar criminal matters in New York State and New York City.

"Winning Business in New York" panel during City & State New York’s Government Procurement Conference
2024-11-14 10:45 - 11:40 (America/New_York)
On November 14th, 2024, Usman Mohammad will be speaking on a panel titled, “Winning Business in New York,” during City & State New York’s Government Procurement Conference: Optimizing Costs, Mitigating Risks, & Enabling Business Growth. The Government Procurement Conference will foster business partnerships between the city and state level government, prime contractors, and small, minority, service-disabled veteran-owned, veteran-owned, and women-owned businesses.
Panel Description:
This panel offers a detailed discussion about the New York procurement process and finding ways to succeed. What are the most effective strategies addressing challenges including the possibility of an economic downturn, methods to winning the bidding process, and making sense of various kinds of RFPs, plus you will hear what NY government entities want from potential contractors.
Moderator:

Carlo Scissura, President, New York Building Congress

Panelists:

Usman Mohammad, Counsel, Kostelanetz LLP
Roman Gofman, Deputy Commissioner, NYC Office of Citywide Procurement
Lisette Camilo, Chief Administrative Officer, Metropolitan Transit Authority
Marc Hiller, General Counsel and Director of Procurement Services, Ostroff Associates, Inc.

Additional information on the event, including registration, is available here.

Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know (CLE)
2024-11-15 13:15 - 14:15 (America/Chicago)
On November 15, 2024, Megan L. Brackney will co-moderate a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” as part of the Practising Law Institute’s “Tax Strategies 2024 – Chicago” programming. Attendees will receive the latest information, strategies, and practical insights available from leading tax practitioners across the United States, along with policymakers from the IRS and the Department of the Treasury.
Course Description:
This panel will focus on the various judicial doctrines and ethical issues that arise in the corporate tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on corporate transactions, including 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.
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions.
Respond to the IRS in an audit.

Moderators:

Megan L. Brackney, Kostelanetz LLP, New York City
Jennifer E. Breen, Morgan, Lewis & Bockius, Washington, D.C.

For full program details and registration information, please click here.
CLE credit is available for this event.

Ethics in Tax: Standards for Tax Advice
2024-11-21 09:00 - 09:55 (America/Los_Angeles)
Kostelanetz LLP partner Megan L. Brackney will kick off the Committee of Banking Institutions on Taxation (CBIT) 2024 Fall Tax Day with a session on November 21, 2024, from 9:00-9:55 AM on ethical standards for dispensing tax advice. Known for her extensive knowledge of tax ethics, Megan regularly educates other tax professionals on how to navigate the complexities of ethical issues in tax practice. Her session will be a valuable opportunity to explore current tax challenges while ensuring adherence to the highest ethical standards.
Fall Tax Day will take place at Arno Ristorante in New York City. The event begins at 8:45 AM and includes a full day of sessions covering topics like tax reporting regulations for digital assets, capital gains reporting, among other types of gains, and foreign trusts. Speakers from other prestigious firms such as PwC, Wolters Kluwer, and KPMG will join, along with insights from government professionals.
The cost to attend is $75 for CBIT Education members and $125 for non-members, with discounted rates available for members’ guests. Tax students and public service professionals may be eligible for waived registration fees. A cocktail reception at 4:30 PM concludes the day’s events.
You can learn more about CBIT’s 2024 Fall Tax Day and register here.
Partner Megan L. Brackney is an experienced tax attorney, Chair-Elect of the American Bar Association Section of Taxation, and an adjunct professor at New York University School of Law. Megan is also former Assistant U.S. Attorney for the Southern District of New York and a frequent speaker and contributor at local and national conferences on taxation, ethics in tax practice, penalties, and tax controversy.

Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know (CLE)
2024-12-13 13:15 - 14:15 (America/Los_Angeles)
On December 13, 2024, Andrew Weiner will co-moderate a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” as part of the Practising Law Institute’s “Tax Strategies 2024 – Los Angeles” programming. Attendees will receive the latest information, strategies, and practical insights available from leading tax practitioners across the United States, along with policymakers from the IRS and the Department of the Treasury.
Course Description:
This panel will focus on the various judicial doctrines and ethical issues that arise in the corporate tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on corporate transactions, including 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.
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions.
Respond to the IRS in an audit.

Moderators:

Andrew Weiner, Kostelanetz LLP, Washington, D.C.
Chad D. Nardiello, Nardiello Turanchik Tompkins LLP, Los Angeles

For full program details and registration information, please click here.
CLE credit is available for this event.

Defending Your Client in the Age of Fraud Enforcement: 2025 International Tax Conference Session
2025-01-09 - 2025-01-10
Kostelanetz partner Caroline Ciraolo is a speaker at the 2025 International Tax Conference taking place January 9-10, 2025, in Miami, Florida.
Caroline’s session, “Defending Your Client in the Age of Fraud Enforcement,” covers tax defense strategies for clients with cross-border activity in the wake of ramped-up IRS enforcement activity. She is presenting with Jeffrey Neiman, a founding partner of Marcus Neiman Rashbaum & Pineiro LLP.
The ITC is sponsored by the Florida Bar Tax Section and the Florida Institute of Certified Public Accountants. The conference is designed for tax professionals who focus on international taxation planning and compliance, international tax controversies, and managing multinational clients’ needs.
CLE credit is available. You can learn more about the conference here.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

Cross-Border Real Estate Investments
2025-02-17 - 2025-02-18
Counsel Eduardo Cukier will speak at the 2025 International Tax Conference hosted by the University of San Diego School of Law and Chamberlain Hrdlicka Law Firm.
Eduardo’s panel, “Cross-Border Real Estate Investments,” will be held on Tuesday, February 18, from 11:15 a.m. to 12:05 p.m. The panel will discuss U.S. and Mexican tax and other considerations of cross-border real estate investments between the U.S. and Mexico. Eduardo will be joined by Patrick W. Martin of Chamberlain Hrdlicka and Rodrigo Adam of HgL Asesores.
The 2025 International Tax Conference will be held at Centro Internacional de Congresos (CIC) in Mérida, Yucatán, México on February 17-18, 2025. Sessions and panels will cover a variety of business, personal, and fiduciary cross-border taxation issues such as cross-border financing, international tax controversies, foreign tax credits, tax treaty considerations, and more. Kostelanetz partner Caroline Ciraolo is also a member of the International Tax Conference’s advisory board.
You can learn more about the conference and register here.
Eduardo focuses his practice on international tax issues concerning multinational businesses and high-net-worth clients. Having many years of experience with taxation and legal frameworks in both the U.S. and Latin America, Eduardo works with both domestic and multinational clients from a wide range of industries on foreign and domestic mergers and acquisitions, business restructuring, and cross-border litigation.

2025 ABA Tax Section Mid-Year Meeting
2025-02-19 - 2025-02-21
Kostelanetz attorneys Michael Sardar, Bryan Skarlatos, and Andy Weiner will speak on various panels of the ABA Tax Section Mid-Year Meeting, of which Kostelanetz is a Diamond sponsor. Our attorneys will demonstrate their knowledge and experience in international tax controversies and other international taxation matters, criminal tax cases, refund litigation, and more.
The ABA Tax Section Mid-Year Meeting will be held February 19-21, 2025, at the JW Marriott LA LIVE event center in downtown Los Angeles. The conference covers a large array of tax law topics and updates from the nation’s leading tax attorneys and authorities. You can learn more about the event and register here.
Please join us for the following panels:
Thursday, February 20, 2025, 10:00 a.m. to 11:45 a.m.
Cross-Functional Current Developments – Part II
Kostelanetz partner Bryan Skarlatos will participate in a panel in the conference’s Corporate & International Track discussing the latest regulatory and case law developments in corporate and individual international taxation. The panel will cover contemporary international tax issues, transfer pricing, and the increasing relevance of the economic substance doctrine in the U.S.
Other participants include Hans Gerling of KPMG; Professor Adam M. Katz of Seton Hall University School of Law; Loren Ponds of Skadden; and Jennifer R. Noel of ChristianaCare, who is moderating the panel.
Friday, February 21, 2025, 8:30 a.m. to 10:15 a.m.
Hot Topics and Common Pitfalls in Refund Litigation
Kostelanetz counsel Andy Weiner joins a panel that will explore the complexities of refund litigation for the conference’s Controversy Track. Panelists will discuss the considerations practitioners must make, and pitfalls they are likely to encounter, in litigating claims for refunds and abatements. Current refund litigation trends will also be discussed, including claims made under the Employee Retention Credit.
Other panelists include Melissa Briggs of Hochman Salkin Toscher Perez P.C.; Jeff Glassman of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP; Gavin Greene from the U.S. Attorney’s Office for the Central District of California; and M. Blair Hlinka of Caplin and Drysdale, Chartered, who is moderating the panel.
Friday, February 21, 2025, 10:30 a.m. to 12:15 p.m.
Keeping it Civil: How to Prevent a Civil Matter from Turning Criminal
Kostelanetz partner Michael Sardar will moderate a panel for the conference’s Controversy Track, discussing how to identify civil tax cases that could potentially become criminal matters. The panel will discuss criteria that often trigger criminal referrals, ethical considerations and strategies for such situations, and common pitfalls that practitioners face when civil matters are at risk of becoming criminal.
Other participants include Jenny C. Lin of Lin Tax Law; John Marston of Sheppard Mullin; Richard Westling of Epstein, Becker & Green, P.C.; and Zhanna A. Ziering of Moore Tax Law Group LLC.
For more than thirty-five years, Bryan has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice.
Michael has extensive experience on a wide range of tax controversy and white-collar criminal defense matters. Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors.
Andy focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. He is also a fellow of the American College of Tax Counsel, and a frequent writer and speaker on tax issues.

IRS Administrative Affairs: Current Developments and Reading the Tea Leaves in Tax Enforcement
2025-02-26
On February 26, 2025, Caroline Ciraolo will speak to Tax Executives Institute’s Detroit Chapter in Levonia, Michigan, about civil tax controversies, including current developments and expectations for tax enforcement in 2025 and beyond. Caroline will present with David Lee with National Tax Controversy Services, Deloitte LLP, who will address IRS administrative affairs and issues facing domestic and multinational entities, including transfer pricing.
Other panelists presenting to the TEI Detroit Chapter on topics including U.S. trade policies include Becky Allen LCB CUSECO, Senior Manager, Global Trade Advisory, Deloitte LLP, and David Reichow, Managing Director, Global Transfer Pricing, Deloitte LLP.
Two hours of CPE credit is available for this program.
Click here for more information and to register. Registration ends at 6 p.m. Thursday, February 20, 2025.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

49th Annual Federal Bar Association Tax Law Conference
2025-02-27 - 2025-03-03
Kostelanetz attorneys Michael Sardar, Melissa Wiley, Andy Weiner, and Will Greco will participate on various panels at the 49th Annual Federal Bar Association Tax Law Conference, of which Kostelanetz is a proud sponsor. Kostelanetz partner Caroline Ciraolo will make keynote remarks at the March 3 luncheon.
During the conference, our attorneys will demonstrate their knowledge and experience in ethical issues in taxation, criminal tax matters, navigating tax administration in a post-Chevron and post-Jarkesy landscape, and more.
Virtual portions of the Federal Bar Association Tax Law Conference will be held February 27-28, 2025. In-person sessions will be held on March 3, 2025, at the Ronald Reagan Building & International Trade Center in Washington, D.C. You can learn more about the conference and register here.
Please join us for the following panels:
Thursday, February 27, 2025, 11:00 a.m. to 12:00 p.m. (Virtual Only, Zoom)
Update on Ethical Issues in Taxation and Circular 230
Kostelanetz attorney Melissa Wiley will participate in a panel of experienced practitioners who focus on ethics and conflicts of interest in federal taxation matters. The panel will cover ethical considerations and responsibilities in light of updates to ABA model rules, state bar rules, and other standards that affect practitioners.
Other participants include Christopher Whitcomb, managing director of KPMG LLP, and Matthew Cooper, principal at Deloitte Tax LLP, who is also moderating the panel.
Thursday, February 27, 2025, 12:30 p.m. to 1:30 p.m. (Virtual Only, Zoom)
Developments in Penalty Controversy and Litigation
Kostelanetz attorney Will Greco will participate in a panel covering important developments in (1) IRS practice in the assertion of penalties, including automatic assessment, transfer pricing, economic substance and excessive refund penalties and (2) litigation regarding various penalties, including Farhy limitations on the assessment of certain penalties, 8th Amendment limitations on FBAR and potentially other penalties, and Jarkesy and 7th Amendment considerations in the tax penalty context.
Other participants include Joy Williamson, partner at Baker & McKenzie LLP, and Ed Froelich, counsel at McDermott Will & Emery, who is also moderating the panel.
Monday, March 3, 2025, 10:45 a.m. to 11:45 a.m. (In Person Only)
What Tax Lawyers Need to Know About the APA in Our New Post-Chevron World
Kostelanetz attorney Andy Weiner will moderate a panel discussing the potential impacts of the Loper Bright Supreme Court case on tax law. Participants will discuss the background of Loper Bright and the APA, what practitioners can expect for various tax rules’ levels of deference post-Chevron, and how Congress can delegate authority.
Other participants include David Foster, partner at Kirkland & Ellis LLP, Aaron Junge, international tax partner at PwC, Arvind Ravichandran, partner at Cravath, Swaine & Moore LLP, and Susan Ryba, partner at McDermott Will & Emery.
Monday, March 3, 2025, 11:45 a.m. – 1:30 p.m. (In Person Only)
Keynote Remarks by Caroline Ciraolo
Kostelanetz partner Caroline Ciraolo will deliver the keynote address during the luncheon program.
Monday, March 3, 2025, 4:00 p.m. to 5:00 p.m. (In Person Only)
When Tax Enforcement Becomes Criminal
Kostelanetz attorney Michael Sardar will co-host a panel on the factors that influence whether IRS criminal investigation agents will seek criminal prosecution. The panel will discuss what IRS-CI agents look for and what the DOJ’s tax division considers when pursuing criminal prosecution, along with the latest trends in criminal tax enforcement.
The panel will be co-run and moderated by Rick Lunger, Division Counsel (Criminal Tax), Office of the Chief Counsel, IRS, U.S. Department of the Treasury.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.
Melissa comes from an actuarial background that grants her a deep understanding of statistics, professional standards, and collaboration with technical, legal, and forensic professionals. Melissa was an assistant general counsel at a Big Four accounting firm with litigation experience in US Tax Court, Court of Federal Claims, and various federal district courts. She focuses her practice on tax controversies, IRS appeals, and representing clients facing government investigation.
Andy focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. He is also a fellow of the American College of Tax Counsel, and a frequent writer and speaker on tax issues.
Will has clerked for the Honorable Mark V. Holmes of the United States Tax Court. He worked on cases concerning the valuations of real property, due process in collections, and complex tax evasion schemes. Will works with clients preparing offers in compromise, requests for audit reconsideration, and other individual representation matters.

Criminal Tax Enforcement at the ABA 40th Annual White Collar Crime Institute
2025-03-04 - 2025-03-07
Kostelanetz partner Caroline Ciraolo will moderate a panel addressing criminal tax matters at the 2025 ABA 40th Annual White Collar Crime Institute, taking place March 5-7, 2025, in Miami, Florida.
The panel is on Wednesday, March 5, 2025, at 10:30 AM and is titled “The Long and Winding Road – From Civil Fraud Referral to Criminal Tax Indictment.” The panelists will review the lifecycle of a criminal tax case that begins as a civil audit or collection matter, travels through the administrative criminal investigation, is referred to the Justice Department (DOJ) Tax Division, and ends with authorization to prosecute. The panelists will discuss what prompts a fraud referral to IRS Criminal Investigation (IRS-CI), how IRS-CI selects its cases, its investigative tools, the applicable standards of review, role of IRS-CI and DOJ Tax conferences, and charging decisions. The panel will also address current criminal tax enforcement priorities, statistics on criminal tax investigations and prosecutions, and cases ripped from the headline.
The ABA White Collar Crime Institute will be held at the Hyatt Regency Miami. There is also an additional Women in White Collar ticketed luncheon and Q&A. You can learn more about the event and register here.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

Gray Proctor Serves as Judge for National Tax Moot Court Competition
2025-03-06 - 2025-03-08
Gray Proctor took up the role of judge for the National Tax Moot Court Competition from March 6-8, 2025 at Stetson University in St. Petersburg, Florida, lending his knowledge and experience to the next generation of tax controversy practitioners.
Gray’s service as a judge is the latest in a long history of service to Floridians. Gray’s tax practice is based out of Kostelanetz’s Atlanta office but he still maintains a separate Florida-centric civil and criminal appellate practice and accepts appointments from federal courts in Florida under the Criminal Justice Act. He is qualified as a board-certified appellate specialist by the Florida Bar Association.
The National Tax Moot Court Competition is hosted by the Tax Section of the Florida Bar. For over 30 years, the event has drawn J.D. and LL.M candidates from around the U.S. to demonstrate their skills in oral arguments and writing briefs. Participants also gain valuable networking opportunities with experienced attorneys to build their tax law careers and gain exposure to variegated tax law practice areas. You can learn more about the competition and stay tuned for 2026 dates here.
About Gray
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal penalties. He also maintains a trial support practice focusing on dispositive motions and other key issues upon which an appeal might follow.
