Kostelanetz LLP

Bryan C. Skarlatos Participates In A Panel Discussion Entitled “Rocks - Partnership Representatives - Hard Places" For The New York State Bar Association Annual Meeting
2019-01-15 16:00 - 17:00 (America/Los_Angeles)
On January 15, 2019, Bryan C. Skarlatos participates in a panel discussion entitled “Rocks – Partnership Representatives – Hard Places” for the New York State Bar Association’s Annual Meeting.
Description: This panel will speak about the challenges facing partnership representatives in IRS audits, and potential solutions to these challenges. The panel will also touch on IRS regulations, MRPC rules, and Circular 230 rules applicable to partnerships.
Panel Chair:

Diana L. Wollman, Cleary Gottlieb Steen & Hamilton LLP

Panelists

Bryan C. Skarlatos, Kostelanetz & Fink LLP; and
Diana S. Doyle, Latham & Watkins LLP

Caroline Ciraolo Presents "What’s New In Tax Enforcement – Current Priorities Of The IRS And DOJ Tax Division" At The Wranglers Law Club
2019-04-18
Caroline D. Ciraolo presents “What’s New In Tax Enforcement – Current Priorities Of The IRS And DOJ Tax Division” at The Wranglers Law Club.

Megan Brackney Presents A Webinar On "Foreign Information Return Penalties And Defenses" For The CPA Academy
2019-04-22
This program covers the basic requirements for reporting non-U.S. assets, and then discusses the penalties for failure to file these foreign information returns and other consequences, the procedures for assessment and review, taxpayer defenses, and options for strategies for taxpayers who want to get into compliance.

Caroline Ciraolo Participates In The Webinar Titled "Tax Advice In The Age Of The 24-hour News Cycle" At The ABA Taxation Section
2019-04-24
Recent instances of exposure by the press of aggressive tax planning and tax avoidance by prominent businesses, individuals or families raise unique substantive, ethical, and other legal issues for the tax community. Practitioners advising famous clients may need to assess not only the likelihood of future examinations, but also public disclosure due to whistleblowers, cooperators, and data leaks.
Reporters investigating past tax compliance may recruit tax professionals for technical assistance and expertise to uncover suspect transactions, unreported income, or improper deductions or credits. The release of such information, and related commentary from various media outlets, may pressure Federal and state tax authorities, law enforcement officials, or regulators to open audits or investigations that could result in substantial tax adjustments and/or various civil and criminal penalties. This panel explored these issues from a variety of perspectives.
Moderator: Professor Lee-Ford Tritt, University of Florida, Gainesville, FL
Panelists: David Caye Johnston, DCReport.Org, Rochester, NY; Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC; Michael H. Plowgian, KPMG LLP, Washington, DC; Professor Michael Lang, Chapman University, Orange, CA

Caroline Ciraolo Presents “Business Or Pleasure? Navigating The Internal Revenue Code When Your Boat Is A Business,” At The Recreational Boating Committee Meeting Of The Maritime Law Association Of The United States
2019-05-02
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Claude M. Millman Delivers Keynote Speech "Attorney Misconduct And Rule 8.4(C): Varsity Blues And Other Examples" At The New York Law School 16th Annual Tax Lawyering Workshop
2019-05-03
Claude M. Millman delivered the keynote address, titled “Attorney Misconduct And Rule 8.4(C): Varsity Blues And Other Examples,” at the New York Law School 16th Annual Tax Lawyering Workshop.
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Sharon L. McCarthy Participates In A Panel Presentation Titled "The Life-cycle Of A Criminal Tax Case" At The 3rd Annual Criminal Tax Day
2019-05-07
This panel walks attendees through the entire life cycle of a criminal tax case: from referral to CI through investigation, Department of Justice Referral, Indictment, Plea and Sentencing. Whether you have worked 10 criminal tax cases before or never been involved in any, our panel brings attendees up to speed with an explanation and exhibits.
Moderator: Eric L. Green, Green & Sklarz LLC, New Haven, CT
Panelists:

Sharon L. McCarthy, Esq., Kostelanetz & Fink, New York, NY
Jeffrey Miller, Supervisory Special Agent, IRS Criminal Investigations, White Plains, NY
Melissa A. Conte, IRS Office of Chief Counsel – Criminal Tax, East Hartford, CT
Michael A. Villa, Jr., Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX

Michael Sardar Participates In A Panel Titled "Asset Protection And Offshore Assets: Hide And Seek In The World Of Divorce" At The AAML/BVR National Divorce Conference
2019-05-09
On May 9, 2019, Michael Sardar participated in a panel titled “Asset Protection And Offshore Assets: Hide And Seek In The World Of Divorce” at the AAML/BVR National Divorce Conference.
Brought to you by the American Academy of Matrimonial Lawyers (AAML) and Business Valuation Resources (BVR), the National Divorce Conference brings together the leading matrimonial attorneys and financial experts for the only event of its kind.
Attendees gained critical insights from nationally recognized presenters and increased their practice proficiency.
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Caroline Ciraolo Participates In The Panel Titled "Collection-based Tax Crimes" At The ABA Section Of Taxation, May Tax Meeting
2019-05-10
Fraud referrals for collection-based tax crimes are on the rise as the IRS seeks to close the tax gap. This panel provides current statistics on, and review of, the tax crimes most likely to be encountered in collection, including willful failure to collect tax, fraud and false statements, and attempts to interfere with the administration of the internal revenue laws. The panelists also discuss practical approaches to handling civil collection cases with criminal implications and how to navigate a criminal collection case.
Moderator: Jonathan Kalinski, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA
Panelists: Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC
Steven Toscher, Hochman Salkin Toscher & Perez PC, Beverly Hills, CA
David Zisserson, Counsel to the Assistant Attorney General for Civil-Criminal Coordination, Trial Attorney, Criminal
Enforcement Section (Southern), Department of Justice, Tax Division, Washington, DC
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Yoram Keinan And Stow Lovejoy Participate In The Panel Titled "The Current State Of The Economic Substance Doctrine And Its Effect On Financial Institutions" At The ABA Section Of Taxation, May Tax Meeting
2019-05-10
The economic substance doctrine was “codified” in 2010, effective for transactions after March 31, 2010, and a new strict liability penalty added for economic substance understatements. While the IRS and Treasury provided initial guidance on the application of the codified doctrine and the penalty, only a handful of cases have considered post-codification transactions. This panel discussed how the economic substance doctrine has developed since codification and the extent to which the doctrine and the penalty should concern financial institutions in planning and examinations.
Moderator: Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY
Panelists: Jasper Cummings, Alston & Bird
James Hartford, Office of Chief Counsel, Internal Revenue Service
Yoram Keinan, Kostelanetz & Fink, LLP
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Caroline D. Ciraolo And Megan L. Brackney Participate In A Panel Titled "Are Your Secrets Safe? A Discussion Of The Scope, Application And Protection Of Legal Privileges In The US And Abroad" At The ABA Section Of Taxation, May Tax Meeting
2019-05-11
Information is power and, in civil audits and criminal investigations, the government seeks to identify and obtain as much information as possible. To the extent such information falls within a recognized legal privilege, it is up to counsel for the taxpayer or target to timely and properly assert the applicable privilege and defend that privilege if the government seeks to compel production. This panel of experienced tax litigation and controversy attorneys addressed the common privileges that arise in tax matters, the holder and scope of those privileges, the extent to which such privileges can be waived or set aside, and how to navigate these waters in foreign jurisdictions and cross-border investigations.
Moderator: Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC
Panelists: Barbara T. Kaplan, Greenberg Traurig LLP, New York, NY; Jenny L. Johnson
Ware, Johnson Moore, Chicago, IL; Megan L. Brackney, Kostelanetz & Fink LLP,
New York, NY; Miriam L. Fisher, Latham & Watkins LLP, Washington, DC; Paula M.
Junghans, Zuckerman Spaeder, Washington, DC
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Michael Sardar Participates In A Panel Presentation Titled "What’s New In Criminal Tax" At The 3rd Annual Criminal Tax Day
2019-05-13
A panel of experts updated attendees on the latest priorities and trends in IRS criminal Enforcement, including cyber-crimes, crypto-currency, marijuana, payroll tax crimes, money laundering, and good-old-fashioned income tax evasion.
Moderator: Lisa E. Perkins, Green & Sklarz LLC, West Hartford, CT
Panelists:

Kristina O’Connell, Special-Agent In-Charge, IRS Criminal Investigation, Boston Field Office
Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ
Michael Sardar, Esq., Kostelanetz & Fink, LLP, Washington, DC

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Jay R. Nanavati Participates In A Panel Presentation Titled "A World Of Lies: The Truth Behind The Tax Protestor Arguments" At The 3rd Annual Criminal Tax Day
2019-05-16
For decades lies and mistruths have been advanced by individuals and groups unhappy with the United States Income Tax. These individuals and groups often twist facts into more suitable positions to advance their agenda. Many of these fabrications were reviewed and dissected in the recent United States Tax Court Decision in Waltner vs. Commissioner. Our esteemed panel reviewed the case and enlightened the attendees to the truth and fiction of the arguments put forth by “tax protestors.”
Moderator: Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Panelists:

Lisa E. Perkins, Esq., Green & Sklarz LLC, West Hartford, CT
Jay R. Nanavati, Esq., Kostelanetz & Fink, Washington, DC

Caroline Ciraolo Participates In A Panel Titled "Current Issues In Government Investigations" At The Federal Bar Association
2019-05-16
Program Topics:

Current trends in Public Integrity Investigations
Follow the Money Trail: The “Other” Counts in the Indictment
Experiences & Insights: A Panel Discussion of Distinguished Jurists with Decades of Experience in the Government, in the Private Sector, and on the Bench

Featuring:
The Hon. John D. Bates, Judge, U.S. District Court for the District of Columbia
The Hon. Catherine C. Blake, Judge, U.S. District Court for the District of Maryland
The Hon. Royce C. Lamberth, Judge, U.S. District Court for the District of Columbia
The Hon. Kenneth W. Starr, Judge (Ret.), U.S. Court of Appeals for the District of Columbia Circuit
Moderated by The Hon. Joe Whitley, former General Counsel, U.S. Department of Homeland Security
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Caroline Ciraolo Participates In A Panel Titled “Exchange Of Tax Information Is Everywhere! Knowing The Rules, Understanding The Landscape,” At The 2019 Audits And Appeals Seminar, Tax Executive Institute
2019-05-21
Sean Akin | Covington & Burling LLP
Caroline Ciraolo | Kostelanetz& Fink LLP
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Caroline Ciraolo Moderates A Panel Titled "Ethical Pitfalls And How To Avoid Them When Representing Clients In IRS Collections And Audits," At The University Of San Diego School Of Law - RJS Law Tax Controversy Institute 2019
2019-07-19
The Institute is the premier tax controversy event in San Diego. The region’s top tax attorneys, CPAs, and law/business school professors discuss topics including passthrough planning, Wayfair, ethical pitfalls to avoid in practice, and employee classification issues in California.
Moderator: Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Panelists: Jonathan Amitrano, Partner, Lavar Taylor
Venar Ayar, CEO, Ayar Law
Dawn Harris, IRS Field Collection Manager, IR
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Caroline Ciraolo Participates In The Panel “Cooperation Or Compulsion: The Emerging U.S. Experience With Voluntary And Involuntary Disclosures Of Foreign Transactions,” At The 37th Annual Cambridge International Symposium On Economic Crime
2019-09-03
In considering how to better discourage and control economic crime we examine the real threats facing our economies and, in particular, those who look after other people’s wealth not just from criminals and terrorists, but also indirectly as a result of law enforcement and regulatory intervention. We also context these risks and the responses not only in terms of the law, but also regulation and especially compliance practice.
Chair: Ian M. Comisky, Partner, Fox Rothschild LLP, Philadelphia and former Assistant US Attorney, Southern District of Florida, USA
Panelists: Don Fort, Chief, Criminal Investigation, Internal Revenue Service, US Department of the Treasury, USA
Larry A. Campagna, Partner, Chamberlain, Hrdlicka, White, Williams & Aughtry, USA
Caroline Ciraolo, Partner, Kostelanetz & Fink LLP and former Asst Attorney General, Tax Division, US DOJ, USA
Sandra R. Brown, Principal, Hochman Salkin Toscher Perez P.C., and former Acting US Attorney, Central District CA, USA
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Caroline Ciraolo Presents "Preserving Confidentiality In Cross Border Investigations," At The 37th Annual Cambridge International Symposium On Economic Crime
2019-09-03
The focus for the 37th symposium is the shared responsibility borne by public and private bodies, across international borders, to fight economic crime. In particular, it looks at the flow of information between agencies and the business world, and how to tackle the issues that this presents. In addition to its keynote speeches and focal discussions each day, there are a host of alternative programmes, plenary sessions and workshops that enable attendees to share their knowledge, garner new skills, and build new connections.
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Robert Russell Participates In A Panel Titled "Diversity In Tax Law" Presented By The Federal Bar Association's Section On Taxation
2019-09-27
On September 27, 2019, Kostelanetz & Fink’s Washington D.C. office hosted the Federal Bar Association’s Diversity in Tax Law event. The event included a moderated panel that explored diversity and inclusion in the practice of tax law followed by a networking reception. The panel was moderated by Bloomberg Tax’s Siri Bulusu and included speakers from different parts of the tax community who discussed their career experiences and the value of a variety of perspectives in tax practice.
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Caroline Ciraolo Participates In Panel Entitled "No Good Deed Goes Unpunished: Potential Liability Of Executors And Beneficiaries For A Decedent’s Tax Liabilities" At Serjeant's Inn
2019-10-02
Caroline Ciraolo participates in a panel entitled “No Good Deed Goes Unpunished: Potential Liability of Executors and Beneficiaries for a Decedent’s Tax Liabilities” at Serjeant’s Inn, Baltimore, MD on October 2, 2019.

Megan L. Brackney Speaks On A Panel Entitled "Recent Developments In Innocent Spouse Litigation" For The Pro Bono & Tax Clinics Committee
2019-10-05 13:00 - 14:00 (America/New_York)
On October 5, 2019, Megan L. Brackney speaks on a panel entitled, “Recent Developments In Innocent Spouse Litigation” for the Pro Bono & Tax Clinics Committee.
Speakers

Megan L. Brackney, Kostelanetz & Fink, LLP;
Julie L. Payne, IRS Office of Chief Counsel;
Christine S. Speidel, Villanova University Charles Widger School of Law; and
Nancy Rossner, The Community Tax Law Project

Megan L. Brackney Participates In A Session Entitled “Anticipating IRS Audits, Controversies, And Litigation Under The Partnership Audit Rules” For The NYU Institute on Federal Taxation's 78th Annual Conference
2019-10-23 17:15 - 18:55 (America/New_York)
Event Description: The NYU Institute on Federal Taxation’s 78th annual conference includes presentations focused on insights and analyses from top tax authorities in America. Sessions are held for five-day periods, including October 20-25 and November 10-15. Substantive sessions are help on prominent tax topics such as tax controversies, international tax, and fundamentals of partnership and real estate taxation.
Session Description: The “Anticipating IRS Audits, Controversies, And Litigation Under The Partnership Audit Rules” session will cover BBA basics, like the timeline of a partnership audit and new terminology used in partnership audits. Requirements to elect out of the BBA, as well as modifications to imputed underpayments will also be explained during this presentation. This session will also cover statutes of limitation, appeals and judicial proceedings, applicable Tax Court rules, penalties, assessing the tax, tax collection, and other special rules related to partnerships.
Session Leaders

Megan L. Brackney, Esq., Kostelanetz & Fink, LLP
Jerald Davidson August, Esq., Fox Rothschild LLP

Caroline Ciraolo Presents "Tax Controversies – IRS Practice Update" At The Sophisticated Tax Planning For Your Wealthy Clients AICPA Conference In Philadelphia, PA
2019-11-18
Caroline D. Ciraolo presents “Tax Controversies – IRS Practice Update” at the Sophisticated Tax Planning for Your Wealthy Clients AICPA Conference on November 18, 2019 in Philadelphia, PA.
The AICPA Sophisticated Tax Planning for Your Wealthy Clients event brings together ideas and tips that will help you strategize better 2020 results for clients.
For more information, please click here.

Stephen A. Josey Participates In The Panel Entitled "Give Me Back My Money: The Life Of A Refund Suit" At The IRS Representation Conference On November 21, 2019
2019-11-21
Stephen A. Josey participates in the panel entitled “Give Me Back My Money: The Life of a Refund Suit” at the IRS Representation Conference on November 21, 2019 in New Haven, CT.
Additional information can be found here.

Usman Mohammad Presents Certain Aspects Of International Tax Law At The "Navigating Challenging Markets Through Alternative Investments" Educational Seminar & Dinner
2019-11-21
The Navigating Challenging Markets Through Alternative Investments Educational Seminar & Dinner was hosted by Arch Global Advisors on November 21, 2019. Usman Mohammad and John Donovan II, CFP covered topics including Financial Planning, Institutional Real Estate and International Tax Law.
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Usman Mohammad Presents The CPE/CLE Course "The Pitfalls Of Foreign Asset Reporting" On December 10, 2019
2019-11-21
This course explored foreign asset reporting on Form 8938, with a focus on issues that can be traps for the unwary. This includes differences between foreign account reporting on Form 8938 versus the FBAR, asset valuation issues that impact certain classes of taxpayers filing Form 8938, and the statute of limitations and civil penalties associated with Form 8938. Usman also discussed suggested best practices in light of these issues.
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Caroline Ciraolo Participates On The Panel "What You Really Need To Know If You Are Taking On A Criminal Tax Case" At The Pennsylvania Association Of Criminal Defense Lawyers 2019 White Collar Practice Seminar In Philadelphia, PA
2019-11-21
Caroline D. Ciraolo participates on the panel “What You Really Need to Know if You Are Taking on a Criminal Tax Case” at the Pennsylvania Association of Criminal Defense Lawyers 2019 White Collar Practice Seminar at The Ritz-Carlton Philadelphia in Philadelphia, PA.
Since its founding in 1988, the Pennsylvania Association of Criminal Defense Lawyers (PACDL) has provided education, resources and more to the Pennsylvania criminal defense bar. Its members are dedicated to ensuring their vision of equal justice under law is the guiding principle of the criminal justice system.
For more information, please click here.

Caroline D. Ciraolo Moderates "A Conversation With Nina Olson, Former National Taxpayer Advocate" At The 2019 New England IRS Representation Conference In Uncasville, CT
2019-11-22
Caroline D. Ciraolo moderates “A Conversation with Nina Olson, Former National Taxpayer Advocate” at the 2019 New England IRS Representation Conference on November 22, 2019 in Uncasville, CT.
The IRS Representation Conference brings together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, appeals, and litigation. The Conference covers a wide range of representation issues, from procedural seminars to substantive programs, estate & gift issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties.
For more information, please click here.

Caroline D. Ciraolo Presents "Criminal Aspects Of IRS Collection Cases" At The 2019 New England IRS Representation Conference In Uncasville, CT
2019-11-22
Caroline D. Ciraolo participates on the panel “Criminal Aspects of IRS Collection Cases” at the 2019 New England IRS Representation Conference in Uncasville, CT, on November 22, 2019.
The IRS Representation Conference brings together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, appeals, and litigation. The Conference covers a wide range of representation issues, from procedural seminars to substantive programs, estate & gift issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties.

For more information, click here.

Sharon L. McCarthy Participates On The Panel "IRS Enforcement Update" At The 2019 New England IRS Representation Conference In Uncasville, CT
2019-11-22
Sharon L. McCarthy Participates on the Panel “IRS Enforcement Update” at the 2019 New England IRS Representation Conference in Uncasville, CT on November 22, 2019.

Voluntary compliance and enforcement of the tax law 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 pay the correct amount of tax. These panel interviews provided us with an update on new developments at the IRS.
SB/SE Update:

Paul J. Mamo, Director, Collection, Internal Revenue Service
Interviewer: Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT

Collections Update:

Paul J. Mamo, Director, Collection, Internal Revenue Service
Interviewer: Frank Agostino, Agostino & Associates PC, Hackensack, NJ

Appeals Update:

Donna Hansberry, Chief, Appeals, Internal Revenue Service
Interviewer: Eric L. Green, Esq., Partner, Green & Sklarz, New Haven, CT

Criminal Update:

Don Fort, Chief, Criminal Investigation, Internal Revenue Service
Interviewer: Sharon L. McCarthy, Esq., Kostelanetz & Fink, LLP, New York, NY

For more information, click here.
