Kostelanetz LLP

Caroline D. Ciraolo Participates In A Panel Entitled “Tips and Traps (or Hot Topics) in Dealing with International Taxpayers and Reporting”
2021-11-04 16:45 - 18:15 (America/New_York)
On November 4, 2021, Caroline D. Ciraolo participates in a panel entitled “Tips and Traps (or Hot Topics) in Dealing with International Taxpayers and Reporting.” This panel is part of the 2021 Annual Meeting of the California Tax Bar and California Tax Policy Conference.
Description: We live in a global economy and many of your clients will have sources of income, investments, assets or activities outside the United States. With these often come complex international tax and reporting obligations, the violation of which can result in substantial civil penalties and, in cases involving willful conduct, criminal exposure. With the automatic exchange of information, increased collaboration among treaty partners, and searches driven by data analytics, it is no longer a matter of if the government will find an offshore asset, but when. This diverse panel will review the common international reporting obligations, potential penalties, applicable statutes of limitations, available defenses, and potential paths to compliance, including the latest developments in voluntary disclosures.
Speakers

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

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The Law Firm Antiracism Alliance Hosts A Discussion Section Entitled “Diversity in the Tax Bar” As Part Of Its Tax System Working Group Discussion Series
2021-11-05 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 Nov. 5, 2021 discussion addresses the current state of diversity in the tax bar and how the legal profession has evolved over the past several decades.
Panelists:

Chief Judge Maurice B. Foley, United States Tax Court
Glenn Carrington, Norfolk State University School of Business
Alice Thomas, Howard University School of Law

Moderator:

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

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Don Fort Participates In A Panel Entitled "Intermediate Discussions Regarding Digital Assets" For The NYSSCPA
2021-11-08 13:30 - 16:50
On November 8, 2021, K&F Director of Investigations Don Fort participates in a panel entitled “Intermediate Discussions Regarding Digital Assets” for the the New York State Society of Certified Public Accountants.
The panelists will discuss, among other things, (1) pricing, regulation, and reporting from digital asset exchanges, (2) custody and control of digital assets, and (3) cryptocurrency investigations/AML and the latest in financial investigations with respect to digital assets.
Speakers

Doug Schwenk, Chairman, Digital Asset Research
Sui Chung, CEO, CF Benchmarks
Kathy Mahoney, Senior Director, FINRA
Anthony Vinci, CPA, MBA, Director, FINRA
Pamela Clegg, CAMS, VP of Financial Investigations, CipherTrace
Nicholas G. Himonidis, JD, CFE, CCFS, CCFI, President, The NGH Group, Inc.
Don Fort, Director of Investigations, Kostelanetz & Fink LLP, Immediate Past Chief of IRS Criminal Investigation Division

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Megan L. Brackney Participates In A PLI Panel Entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know”
2021-11-11 14:15 - 15:15
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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Caroline D. Ciraolo Speaks At The 4th Annual White Collar Institute Hosted By Lightfoot, Franklin & White, LLC
2021-11-18 09:30 - 19:30
On November 18, 2021, Caroline D. Ciraolo speaks at the 4th annual White Collar Institute hosted by Lightfoot, Franklin & White LLC. This event covers a variety of civil, criminal, and regulatory issues for businesses.
Description: The White Collar Institute brings together a national faculty of lawyers, judges and academics who share insights into the latest developments in white-collar criminal and civil enforcement. This year, it is taking place in Houston at The Houstonian Hotel, Club & Spa (111 N Post Oak Lane). There is an online option for those who can’t make it in person, or who are not from the Houston area.
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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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Megan L. Brackney Presents “Defining the Reasonable Cause Defense to Tax and Information Reporting Penalties” For Lawline
2021-12-03 14:00 - 15:00
On December 3, 2021, Megan L. Brackney presents “Defining the Reasonable Cause Defense to Tax and Information Reporting Penalties” for Lawline.
“Reasonable cause” is a defense to most penalties in the Internal Revenue Code. This program discusses how “reasonable cause” is defined in various contexts, including delinquency penalties, accuracy penalties, foreign information return penalties, and penalties for noncompliance, such as failure to file Forms 8300 and to issue tax reporting forms, such as Forms W-2 and 1099. The program (1) reviews the concepts of “reasonable cause” as a defense to tax penalties, (2) discusses Code sections, Treasury Regulations, and case law defining “reasonable cause” in different contexts, and (3) identifies techniques for presenting “reasonable cause” defenses to penalties.
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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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Megan L. Brackney Presents A CLE Program Entitled “Preparing for a Tax Controversy: Gearing Up for Increased Tax Audits and Investigations" For The American Law Institute
2021-12-07 12:00 - 13:00
On December 7, 2021, Megan L. Brackney presents a CLE Program entitled “Preparing for a Tax Controversy: Gearing Up for Increased Tax Audits and Investigations” for the American Law Institute.
Description: In an August letter to IRS Commissioner Charles Rettig, members of Congress asked for increased IRS funding to pursue wealthy tax evaders and improve IRS services for all Americans. If successful, the current budget reconciliation package will deliver this requested funding to the IRS. The downstream effect will have significant impacts on attorneys advising clients in tax, business, or wealth planning matters. They will see increasing numbers of IRS audits, assessments, and tax collections against their high-net worth and business taxpayers, both at home and abroad. Become better prepared for further IRS scrutiny on the horizon, including audits, litigation, and even criminal investigations by registering for this deep-dive program.
There are suspect items on tax returns that the IRS has identified as prime candidates for detailed review and document production – learn what will be scrutinized and how to prepare yourself, after attending this video webcast. You’ll be better prepared to appreciate client obligations before conflicts ripen and will improve your conflict resolution skills with the solutions taught by this exceptional faculty. You and your client cannot afford to be unprepared for an IRS tax controversy and the practical guidance shared during this program will be your ultimate resource on IRS controversies. Our two nationally recognized tax experts will guide you through:
IRS Large Business and International Compliance Campaigns

Taxable Asset Transactions—Matching Buyers and Sellers
Tax Cuts and Jobs Act of 2017 Campaign
Financial Service Entities Engaged in a U.S. Trade or Business Campaign
U.S. Territories—Erroneous Refundable Credits and Individuals Claiming Income Tax Residence in Puerto Rico
Virtual Currency Taxation and Compliance
Corporate Direct Foreign Tax Credits
Expatriation of Individuals
FIRPTA Reporting Compliance for Non-resident Aliens
Related Party Transactions Campaign

Global High Wealth Group

The “Revived Global High Wealth Group”—What to Expect

High Net Worth Non-filers and Forms 3520/3520-A Non-Compliance

Repatriation of Foreign Earnings and Profits and Related Areas
Dual Residency Issues

Handling Audits Before the IRS Examination Division

Responding to IRS Requests for Information—-Circular 230 Rules
Information Requests and Summons, Including John Doe Summons

Advising Clients in Sensitive IRS Audits and Examinations; Assessing Risks

Privileges and Ethical Considerations

Speakers:

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

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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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Michael Sardar And John D. (Don) Fort Participate In A "Criminal Tax Workshop" At The ABA's 38th Annual Criminal Tax Fraud Institute And 11th Annual Civil Tax Controversy Institute
2021-12-08 14:30 - 17:00
On December 8, 2021, Michael Sardar and John D. (Don) Fort participate in a “Criminal Tax Workshop” at the ABA’s 38th Annual Criminal Tax Fraud Institute and 11th Annual Civil Tax Controversy Institute.
Description: This popular workshop will teach you strategies and techniques for handling sensitive civil examinations and criminal investigations and defending a criminal prosecution. The workshop addresses when to anticipate a criminal referral, IRS Special Agent interviews of the taxpayer or preparer, representation of a target, subject or witness in a criminal investigation, how to approach a Department of Justice conference, procedural and trial issues that every criminal tax defense attorney should know, when and how to argue tax loss issues, effective plea negotiations, and sentencing strategies. The workshop includes a “criminal tax toolkit” of practice tips prepared by experienced practitioners
Moderators:

Justin Gelfand, Margulis Gelfand
Michelle Feit Schwerin, Capes Sokol

Speakers:

Michael Sardar, Kostelanetz & Fink, LLP
John D. (Don) Fort, Kostelanetz and Fink, LLP
Ian T. Murphy, Margulis Gelfand
Elizabeth Hadden, Internal Revenue Service
Edward M. Robbins, Jr., Hochman Salkin Toscher Perez, P.C.
Martin Schainbaum, Martin A. Schainbaum, A Professional Law Corporation
Richard Speier Jr., Richard Speier & Associates
Lacey Strachan, Hochman Salkin Et Al PC

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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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Bryan C. Skarlatos And Don Fort Teach A Course Entitled “When Aggressive Tax Planning Becomes Criminal Tax Fraud: Crossing the Line” For CPA Academy
2021-12-22 13:00 - 14:00
On December 22, 2021, Bryan C. Skarlatos and Don Fort teach a course entitled “When Aggressive Tax Planning Becomes Criminal Tax Fraud: Crossing the Line” for CPA Academy.
Course Description: Nobody wants to pay more taxes than they have to and nobody should pay more than is truly required under the law. But where is the line between legitimate tax planning and criminal tax fraud? In this session, the former Chief of the IRS Criminal Investigation Division and an experienced tax fraud and tax ethics attorney will discuss exactly where that line is and how you can protect your clients, and yourself, from allegations of criminal conduct.
Learning Objectives:

Identify what conduct is criminal
Determine how the IRS chooses and investigates cases
Recall current IRS priorities so you know what the IRS is looking for

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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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Megan L. Brackney Teaches A Course Entitled “Ethical Issues in Practice Before the IRS” For CPA Academy
2022-01-13 13:00 - 14:00
On January 13, 2022, Megan L. Brackney teaches a course entitled “Ethical Issues in Practice Before the IRS” for CPA Academy.
Course Description: This session covers the provisions of Circular 230 and the AICPA Statements on Standards for Tax Services that apply when interacting with the IRS during audits, appeals, collection matters, and other circumstances. Megan L. Brackney discusses the duty to provide information to the IRS and to not prolong the proceedings, diligence as to the accuracy of information presented to the IRS, and reliance on clients for information. She also discusses the civil and criminal penalties that apply to practitioners who violate these standards.
Learning Objectives:

Recognize the ethical rules that apply when interacting with the IRS
Determine when it is reasonable to rely on clients for information that is being presented to the IRS
Recall potential civil and penalties that apply to practitioners who run afoul of these rules
Present tips for dealing with clients on these issues and correcting any misstatements made to the IRS

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