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

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

Click here for more information and to register.

Bryan C. Skarlatos Presents A Virtual Course Entitled “Ethical Issues In Everyday Tax Practice: When Are You Crossing A Line?" At The Golden Gate University's Annual Tax Update Conference
2022-02-03 14:00 - 15:00
On February 3, 2022, Bryan C. Skarlatos presents a course entitled “Ethical Issues In Everyday Tax Practice: When Are You Crossing A Line?” at the Golden Gate University’s Annual Tax Update Conference. Please note that the live presentation occurs on February 3, 2022 and a rebroadcast of the presentation occurs on February 17, 2022 at 12:00 pm during which Bryan C. Skarlatos is available through live chat. CPE credit is offered for this event.
Description: Tax law is complicated, and the answers are not always clear. Join Bryan Skarlatos for this presentation on ethical questions faced by most tax practices. This session addresses questions such as:

How sure you have to be before you tell a client it is okay to take a position on a tax return, such as deducting an expense or deferring income?
Do you have to audit a client’s records or can you just rely on what the client says?
What is the difference between ordinary tax advice and criminal tax evasion?
How do you protect your client and yourself from civil and criminal penalties?

Learning Objectives:

Identify ways to provide your clients with the best advice possible
Identify ways to avoid penalties and comply with your ethical obligations

Speaker:

Bryan C. Skarlatos, Partner, Kostelanetz & Fink, LLP

Click here for more information and to register.

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

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

Moderator:

Sabrina Conyers, McGuire Woods LLP

Click here to register.

Don Fort Speaks At The Association Of Certified Financial Crime Specialists' Future Of FinCrime Skills Summit
2022-02-15 09:00 - 10:30
On February 15, 2022, Don Fort speaks on “The Present and Future of FinCrime Investigations” at the Association of Certified Financial Crime Specialists’ Future of FinCrime Skills Summit.
Description: To know where we’re going, we have to understand where we’ve been… and perhaps more importantly, where we are currently. This old adage holds true in the investigative arena. Effective investigations in the public and private sectors remain at the heart of fincrime detection and prevention, even as tech disruption, new financial products and emerging criminal typologies threaten to upend investigative work. In this session, experts provide their take on some of the most pressing questions facing fincrime investigators – how is the skillset of an investigator or analyst changing? What’s required for individuals and organizations to adapt and thrive in a more data-driven, automated and real-time financial world? And what does the future hold?
Speaker:

Don Fort, Director of Investigations, Kostelanetz and Fink, LLP

Click here for more information and to register.

Claude M. Millman Leads A Webinar Entitled “Contract Essentials for Nonprofits" For NYLPI
2022-02-22 10:00 - 11:30
On February 22, 2022, Claude M. Millman leads a webinar entitled “Contract Essentials for Nonprofits” for New York Lawyers for the Public Interest, Inc. (NYLPI).
Description: Regardless of their size and programming, all nonprofits must deal with contracts as part of their routine operations. In this virtual training, Claude M. Millman provides essential information about contracts that every nonprofit should know before signing on the dotted line.
Click here for more information.

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

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

Panelists:

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

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

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

Moderator:

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

Panelists:

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

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

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

Panelists:

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

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

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

Panelists:

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

Click here for more information and to register.

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

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

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

Don Fort Presents A CPE Webinar Entitled “Criminal Tax Fraud Overview: Crossing the line from Civil to Criminal” For MyCPE
2022-04-26 14:30 - 15:30
On April 26, 2022, Don Fort presents a CPE webinar entitled “Criminal Tax Fraud Overview: Crossing the line from Civil to Criminal” for MyCPE.
Description: Where is the line between legitimate tax planning and criminal tax fraud? There are two types of federal income tax fraud: civil and criminal. Although these two concepts are related and even intertwined to some extent, they do have significant differences. For starters, civil tax fraud generally results in penalties asserted against a taxpayer whereas criminal tax fraud generally results in jail time or probation. Significantly, however, a taxpayer can be liable for both civil tax fraud and criminal tax fraud with respect to the same activity or activities, i.e., the Government can assert both sanctions against a wrongful taxpayer. In this course, Don Fort shares his expertise in understanding the difference between civil and criminal tax matters. CPE credit is offered for this event.
Learning Objectives:
After attending the session, the participant will be able to:
Identify what conduct is criminal;
Analyze how IRS Criminal Investigation chooses criminal cases;
Analyze the difference between civil tax matters and criminal tax matters;
Discuss the steps that IRS Criminal Investigation investigates cases;
Inspect IRS Criminal Investigation priorities so you know what the IRS is looking for.
Presenter: Don Fort, Director of Investigations, Kostelanetz & Fink, LLP
Click here for more information and to register.

Jay Nanavati Participates In A Panel Entitled "The Corporate Transparency Act and Treasury's New Beneficial Ownership Disclosure Rules: Potential Impacts on Financial Crimes Investigations and Tax Controversies" Hosted By Miller & Chevalier
2022-04-26 16:30 - 17:30
On April 26, 2022, Jay Nanavati participates in a panel discussion entitled “The Corporate Transparency Act and Treasury’s New Beneficial Ownership Disclosure Rules: Potential Impacts on Financial Crimes Investigations and Tax Controversies” hosted by Miller & Chevalier.
Description: The U.S. Department of the Treasury (Treasury) is in the midst of a multi-stage rulemaking, implementing the Corporate Transparency Act of 2021 (CTA) and attempting to crack down on the use of U.S.-based companies to evade taxes, launder money, and commit fraud. Rules proposed thus far would require many entities to provide detailed reporting to Treasury on their beneficial ownership for the first time, and additional proposed rules will follow. Panelists discuss:

The conditions giving rise to the CTA
The provisions of the proposed rules
The next steps in the rulemaking
Related developments in federal law enforcement’s use of financial institution reporting
Ramifications for criminal tax investigations, other white collar investigations and civil tax controversies.

Moderator:

Joseph Rillotta, Member, Miller & Chevalier

Panelists:

Dennis Kihm, Section Chief, Depository Institutions, Financial Crimes Enforcement Network (FinCEN)
Melissa L. Wiley, Member, Caplin & Drysdale
Jay R. Nanavati, Partner, Kostelanetz & Fink
Ian Herbert, Counsel, Miller & Chevalier

This event is available to attend in-person, with a cocktail hour to follow, or remotely via Zoom. Please RSVP by 5:00 p.m. EDT on Friday, April 22, 2022.
Click here to RSVP for in-person.
Click here to RSVP for Zoom.

Caroline D. Ciraolo Participates In A Panel Entitled "Targeting the Oligarchs: New Tax Transparency Initiatives, Sanctions, Seizures, and Freezes" For The ABA's 2022 ILS Annual Conference
2022-04-28 09:00 - 10:30
On April 28, 2022, Caroline D. Ciraolo participates in a panel entitled “Targeting the Oligarchs: New Tax Transparency Initiatives, Sanctions, Seizures, and Freezes” for the 2022 International Law Section (ILS) Annual Conference hosted by the American Bar Association (ABA).
Description:
Tax transparency is omnipresent and ever increasing, replacing financial privacy. Today, there is automatic exchange of information, financial, transactional and ultimate beneficial ownership information reporting, unilateral and multilateral investigations and international cooperation. These initiatives have resulted primarily because of governmental needs for revenue and the recognition that information can curb international tax evasion scandals. Now, with the horrific events in Ukraine, governments are taking an even more proactive approach, not only seeking to sanction bad actors, but also seeking to freeze and seize assets, and ultimately, to establish a global wealth register. This program covers these developments from the perspective of the US, the UK and the EU. CLE credit is offered for this event.
Program Chair:

Pamela A. Fuller, Counsel, Zahn Law Group, New York, NY

Moderator:

Alan Winston Granwell, Of Counsel, Holland and Knight LLP, Washington, DC

Speakers:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP, Washington, DC
Nicola Saccardo, Partner, Maisto e Associati, London, United Kingdom (virtual)
Emma-Jane Weider, Managing Partner, Maurice Turnor Gardner LLP, London, United Kingdom (virtual)

Click here for more information and to register.

Megan L. Brackney Participates In A PLI Panel Entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know”
2022-04-28 17:00 - 18:30
On April 28, 2022, 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 Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2022 Chicago” hosted by the Practising Law Institute (PLI).
Description: The panelists review the ethical rules related to advising clients on transactions involving partnerships and other passthrough entities, using a real-life hypothetical, 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. Ethical rules covered by the panelists include 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.
Panelists

Megan L. Brackney, Partner, Kostelanetz & Fink, LLP; and
Jenny L. Johnson Ware, Partner, McDermott Will & Emery, LLP.

Click here for more information and to register.

Christopher M. Ferguson Participates In A Panel Entitled “So Your Client Wants to Pay You in Cryptocurrency…” For The New York Law School 19th Annual Tax Lawyering Workshop
2022-04-29 09:15 - 10:30
On April 29, 2022, Christopher M. Ferguson participates in a panel entitled, “So Your Client Wants to Pay You in Cryptocurrency…” for the Graduate Tax Program at New York Law School’s 19th Annual Tax Lawyering Workshop: Tax Practice In A Changing World.
The program meets virtually via Zoom and offers Ethics CLE Credits (NY transitional and non-transitional).
Moderator:

Ann F. Thomas, Otto L. Walter Distinguished Professor of Tax Law; Director, Graduate Tax Program, NYLS

Panelists

Christopher M. Ferguson, Partner, Kostelanetz & Fink LLP
Houman Shadab, Professor of Law; Director, Innovation Center for Law and Technology, NYLS

Caroline D. Ciraolo Delivers Opening Remarks For A Panel Entitled "Breaking Down Barriers To Effectuate Change in the Legal Field" Hosted By The Federal Bar Association's Section On Taxation
2022-05-04 12:00 - 13:30
On May 4, 2022, Caroline D. Ciraolo delivers opening remarks for a panel entitled “Breaking Down Barriers To Effectuate Change in the Legal Field” hosted by the Federal Bar Association’s Section on Taxation.
Description:
In this virtual panel, distinguished justices on the U.S. Tax Court discuss how they navigated the legal field throughout their trail-blazing careers and practices that can lead to a more diverse, inclusive, and equal environment in the legal field.
Opening Remarks:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Drita Tonuzi, Deputy Chief Counsel (Operations), IRS, Office of Chief Counsel

Moderators:

Paulmikell “PM” Fabian, IRS, Office of Chief Counsel
Renan Rodriguez, Weil, Gotshal & Manges, LLP

Panelists:

Hon. Maurice B. Foley, Chief Judge, U.S. Tax Court
Hon. Courtney D. Jones, Judge, U.S. Tax Court
Hon. Juan F. Vasquez, Judge, U.S. Tax Court
Hon. Eunkyong Choi, Special Trial Judge, U.S. Tax Court

Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Tax Litigation Update including Recent Decisions and their Impact on Corporate and Individual Taxpayers" For The Tax Legislative And Regulatory Update Conference Hosted By The DC Bar
2022-05-04 14:00 - 15:30
On May 4, 2022, Caroline D. Ciraolo participates in a panel entitled “Tax Controversy: Tax Litigation Update including Recent Decisions and their Impact on Corporate and Individual Taxpayers” for the Tax Legislative and Regulatory Update Conference hosted by the DC Bar Taxation Community.
Moderator:

Michael Desmond, Partner, Gibson Dunn & Crutcher LLP

Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP and Adjunct Professor of Law, The Georgetown University Law Center
Miriam Fisher, Partner, Latham & Watkins, LLP
Tax Division, U.S. Department of Justice (TBD)

Click here for more information and to register.

Don Fort Participates In The 2022 Government Analytics Leadership Forum For Canadian Government Officials
2022-05-10 09:00 - 10:00
On May 10, 2022, Don Fort discusses how tax agencies can shine a light on the shadow economy and address compliance challenges head on, using cloud computing, advanced algorithms, and public data on the web at the 2022 Government Analytics Leadership Forum. Underreporting of business income and sales have been age-old problems for tax agencies around the world, and the digital economy increasingly exacerbates the issue by enabling complicated transactions and blurring the lines between the physical and digital worlds. SAS and IVIX have partnered together to set a bold goal of creating unprecedented economic transparency across the global economy.
Description:
Governments globally are trying to maximize technology benefits to protect and service the public and support crucial investment decisions. But they’re challenged by fraud and improper payments, security threats that can even threaten physical infrastructure, and the inability to obtain insights from the vast quantities of data government organizations produce daily.
Join the 2022 Government Analytics Leadership Forum May 3 and May 10 to learn how SAS and its partners can help the public sector address real challenges brought about by change and an acceleration of technology adoption.
Click here for more information and to register.

Bryan C. Skarlatos Participates In A PLI Panel Entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know”
2022-05-11 16:00 - 17:30
On May 11, 2022, Bryan C. Skarlatos participates in a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” for “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2022 New York City” hosted by the Practising Law Institute (PLI).
Description: The panelists review the ethical rules related to advising clients on transactions involving partnerships and other passthrough entities, using a real-life hypothetical, 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. Ethical rules covered by the panelists include 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.
Panelists

Bryan C. Skarlatos, Partner, Kostelanetz & Fink, LLP; and
Michael J. Desmond, Partner, Gibson, Dunn & Crutcher LLP.

Click here for more information and to register.

Jay Nanavati Participates In A Panel Entitled "Targeting Tyrants, Toadies, Tax Evaders, Oligarchs, and the Ostensible Gatekeepers" For The ABA’s Hybrid 2022 May Tax Meeting
2022-05-13 09:15
On May 13, 2022, Jay Nanavati participates in a panel entitled, “Targeting Tyrants, Toadies, Tax Evaders, Oligarchs, and the Ostensible Gatekeepers” for “Hybrid 2022 May Tax Meeting” hosted by the American Bar Association’s Section of Taxation.
Description: Navigating the new tax & transparency policies aimed at unmasking “beneficial owners” and stopping the shell games. For decades, offshore financial centers have competed fiercely with each other to attract wealthy individuals and families by offering them not only low tax rates, but also a private place to protect their assets from creditors and regulators. Circuitous investment strategies — involving tiers of shell companies, private banks, and Wall Street connections — have facilitated the “legal” placement of billions of dollars with prominent US hedge funds and PE firms. Despite KYC compliance, the true beneficial owners often remain anonymous, allowing every “gatekeeper” (i.e., attorneys, accountants, and investment advisors) plausible deniability — i.e., the ability to honesty say that he or she was not knowingly working directly for an illicit enterprise. In December 2021, FinCEN issued proposed regulations implementing the 2020 Corporate Transparency Act, the purpose of which is to create a national “beneficial ownership registry,” and to combat, to the broadest extent possible, the proliferation of anonymous shell companies that facilitate the flow and sheltering of illicit money in the United States. Meanwhile, Russia’s invasion of Ukraine has had this unexpected side effect: demonstrating that the complex offshore financial system can dismantle itself. In March 2021, the IRS asked Congress for more resources in implementing the Biden Administration’s sanctions program, along with DOJ’s “kleptocracy task force.” Senator Wyden has introduced a bill to eliminate certain tax and treaty benefits for Russian oligarchs. On a multilateral level, the US Treasury has joined other countries to launch the “Russian Elites, Proxies, and Oligarchs (REPO) multilateral task force. Panelists will discuss these new tax policy and transparency initiatives, and their implications for practitioners, including new due diligence concerns, the attorney-client privilege, the duty of confidentiality, and compliance issues in identifying the true “beneficial owners” of complex structures, and reporting to FinCEN the names of the professionals who helped create them.
Moderator:

Pamela A. Fuller, Tully Rinckey, Zahn Law

Panelists:

Alan Granwell, Holland & Knight, LLP
Bruce Zagaris, Berliner, Corcoran & Rowe, LLP
Jay Nanavati, Kostelanetz & Fink, LLP
Marco Rossi, Marco Q. Rossi & Associati, PLLC

This event is available to attend in-person or remotely.
Click here for more information and to register.

Megan L. Brackney Participates In A Panel Entitled “Moral and Ethical Duties Around Diversity, Equity, and Inclusion” For The ABA's Hybrid 2022 May Tax Meeting
2022-05-13 15:10
On May 13, 2022, Megan L. Brackney participates in a panel entitled, “Moral and Ethical Duties Around Diversity, Equity, and Inclusion” for “Hybrid 2022 May Tax Meeting” hosted by the American Bar Association’s Section of Taxation.
Description: Fostering a workplace environment for different voices, perspectives, and backgrounds provides a space where employees feel welcome to express their ideas and be heard. However, without inclusive leadership and recognition of bias, organizations may miss an opportunity to hear new ideas or even the concerns of their employees. This panel will engage in a discussion about the intersection of ethics and diversity, equity, and inclusion (DE&I). In evaluating the ethical duties in tax practice, panelists will identify where tax practitioners have a professional responsibility to promote diversity, equity, and inclusion in their practice. Panelists will also discuss the moral case for DE&I in tax practice – what should we be doing as tax professionals.
Learning Objectives:
After attending the session, the participant will be able to:

Identify professional responsibility rules for tax practitioners and how these rules relate to diversity, equity, and inclusion efforts;
Discuss what tax practitioners can do to make impactful changes in achieving a diverse and inclusive profession; and
Identify how implicit bias within office management may impact diverse attorneys.

Moderator:

Catherine Sullivan, IRS Office of Chief Counsel

Panelists

Megan L. Brackney, Kostelanetz & Fink, LLP;
David Farhat, Skadden, Arps, Slate, Meagher & Flom, LLP; and
Additional Panelists TBA

This event is available to attend in-person or remotely.
Click here for more information and to register.

Jay Nanavati Participates In A Panel Entitled "Search Warrants, Subpoenas and Summonses: Recent Taxpayer Challenges and Legal Developments" For The ABA’s Hybrid 2022 May Tax Meeting
2022-05-14 09:40
On May 14, 2022, Jay Nanavati participates in a panel entitled, “Search Warrants, Subpoenas and Summonses: Recent Taxpayer Challenges and Legal Developments” for “Hybrid 2022 May Tax Meeting” hosted by the American Bar Association’s Section of Taxation.
Description: During criminal tax investigations, the Government has many evidence-gathering tools and processes at its disposal, including search warrants, subpoenas and summonses. In civil tax cases, the Government frequently
uses summonses to gather information and documents. This panel will discuss the Government’s use of these
tools, recent taxpayer challenges, including those involving the use of filter teams, and legal developments in this
area. The panel will also discuss best practices for representing your clients and protecting privileges when you
learn of a search warrant, or service of a summons or subpoena. CLE credit is offered for this event.
Moderator:

Sara Neill, Shareholder, Capes Sokol

Panelists:

Caryn Finley, Assistant United States Attorney, Western District of North Carolina;
Jay Nanavati, Kostelanetz & Fink, LLP; and
S. Starling Marshall, Crowell & Moring, LLP

This event is available to attend in-person or remotely.
Click here for more information and to register.

Don Fort Participates In Keynote Fireside Chat At ACAMS Law Enforcement Anti-Financial Crime Seminar
2022-05-16 09:10 - 10:00
On May 16, 2022, Don Fort participates in a keynote fireside chat at the two-day virtual Law Enforcement Anti-Financial Crime Seminar of ACAMS, the largest international membership organization for Anti-Financial Crime professionals. Moderating the fireside chat is Jim Lee, Chief of the Internal Revenue Service-Criminal Investigation (IRS-CI).
Description: Law enforcement is on the front lines of fighting financial crime — and those lines are shifting amid emerging threats and increasingly sophisticated criminals. ACAMS first Law Enforcement Anti-Financial Crime Seminar brings information-rich sessions, led by seasoned investigators from the public and private sectors. From cybercrime to cryptocurrencies, public-private partnerships to preparing cases for trial, attendees gain expertise for immediate professional benefit and invaluable insights for mastering this fast-changing environment.
Featured Sessions:
– Best Practices in Organizing and Executing Financial Crime Investigations
– Understanding the Inner Workings of Financial Institutions’ Anti Financial Crime Programs As An Asset to Your Investigations
– Enhancing Your Subpoena Process for More Effective Financial Crime Investigations
– Forging Public-Private and Inter-Agency Alliances to Foster Information Sharing and Strengthen Investigations
– Addressing Criminal Typologies of FinTech, Crypto and Other Payment Processors
– Building an Effective Financial Fraud and Money Laundering Case for Trial
– Using Seizure Warrants to Support Financial Crime Investigation
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Megan L. Brackney Presents In A Webinar Entitled “Ethical Dilemmas - The IRS's Enforcement of Foreign Information Return Penalties and the Practitioner's Duty to Promote Compliance” For The International Tax Institute
2022-05-17 13:00 - 14:00
On May 17, 2022, Megan L. Brackney presents in a webinar entitled, “Ethical Dilemmas – The IRS’s Enforcement of Foreign Information Return Penalties and the Practitioner’s Duty to Promote Compliance” for the International Tax Institute.
Presenters

Megan L. Brackney, Kostelanetz & Fink, LLP;
William E. (“Buck”) Buchanan, Grant Thornton; and
Katrina Robinson, Teton Trust Company

The International Tax Institute offers 1 hour of New York CLE and New York CPE credit for this webinar. Instructions for qualifying for CLE and CPE credit will be provided during registration and at the start of the webinar.
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Don Fort Participates In A Panel Entitled "The US Treasury's National Illicit Finance Strategy: A Closer Look" with AML RightSource
2022-05-18 15:00
On May 18, 2022, Don Fort participates in a panel entitled “The US Treasury’s National Illicit Finance Strategy: A Closer Look” with AML RightSource.
Description: Members of the AML RightSource Advisory Board will provide their insight on the U.S. Department of the Treasury’s 2022 National Illicit Finance Strategy, a comprehensive and potentially far-reaching document that among other things highlights:

The illicit finance risk posed by the abuse of legal entities;
The complicity of professionals that misuse their positions or businesses;
Small-sum funding of domestic violent extremism networks;
The effective use of front and shell companies in proliferation finance;
The exploitation of the digital economy

Panelists:

Don Fort, Director of Investigations, Kostelanetz and Fink, LLP
Rick Small, Executive Vice President and Director, Financial Crimes Program, BB&T
Teresa (Terry) Pesce, President and CEO, Terry Pesce & Co LLC
John Byrne, Executive Vice President and Chairman, AML RightSource

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

Joshua Odintz, Holland & Knight, United States

Panelists:

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

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Megan L. Brackney Participates In A Panel Entitled “Coming in from the Cold: Dealing with Non-Filers” For The TRN's Forensic Accounting Summit
2022-05-20 08:40 - 10:00
On May 20, 2022, Megan L. Brackney participates in a panel entitled, “Coming in from the Cold: Dealing with Non-Filers” for the Forensic Accounting Summit, an all-day program hosted by the Tax Rep Network.
Event Description: Taxes are at the heart of our economic engine. Though we have a “voluntary tax system,” it’s not THAT voluntary! The IRS makes a point of pursuing taxpayers who fail to uphold their end of the bargain and is currently pursuing the more than 10 million non-filers, many of whom are high-income earning. This full-day conference will bring experts from around the country together to review how the process works to bring in non-filers, handle the IRS, and what to watch out for to protect yourself from ethical pitfalls. It will also review reconstruction techniques that come up far too often in bankruptcies, divorce, and civil and criminal tax matters, with an emphasis on how to present the information to the IRS. Finally, we will review how to lay the groundwork early to avoid or abate penalties when these issues arise.
Panel Description: The IRS is pursuing more than 10 million non-filers that they have already identified, plus countless others that get swept up in ongoing audits and investigations. For those taxpayers not yet contacted, interesting decisions await: to simply file or submit a request to be pre-cleared into voluntary disclosure? And which one is best for what situation? Our panel of professionals will review the current state of voluntary disclosure, how to determine which option is best for the client, and how to bring them in without triggering a criminal referral.
Moderator:

Eric L. Green, Esq., Green & Sklarz LLC

Panelists

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

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

Christopher M. Ferguson, Partner, Kostelanetz & Fink LLP

Caroline D. Ciraolo Participates In A Panel Entitled "Aggressive Tax Enforcements: You Can Run but Cannot Hide…" For The Cambridge Forums Forum on International Tax & Disputes
2022-05-27
On May 27, 2022, Caroline D. Ciraolo and Stephanie Kamp LL.M., stetter Rechtsanwaite, Munich, Germany, moderate a group discussion titled, “Aggressive Tax Enforcements: You Can Run but Cannot Hide…” at the International Tax & Disputes Forum, hosted by Cambridge Forums in Surrey, United Kingdom.
Description:
In the face of substantial and rising Tax Gaps, limited resources, and complex and sophisticated abusive transactions, tax authorities around the world are looking to leverage available tools and relationships to identify potential tax offenders, investigate the conduct, and hold those violating the tax laws accountable. These efforts include the use of bilateral and multilateral treaties and agreements to obtain information and documents across borders. The Joint Chiefs of Global Tax Enforcement, established in 2018 by the United States, the United Kingdom, Canada, the Netherlands, and Australia, is just one example of the collaboration among treaty partners that is leading to the increase in domestic and international criminal tax investigations. Taxpayers and their advisors need to be aware of developments on the world stage and understand the implications for criminal tax enforcement. Attendees will discuss global tax enforcement priorities, investigative tools, cross-border investigations, and resource allocations.
Forum on International Tax & Disputes
The Steering Committee welcomes up to 40 senior tax directors and leading lawyers personally selected from renowned regional and national firms and corporations around the world. With increased transparency and information sharing amongst tax authorities, as well as the use of aggressive techniques like criminal investigations and digital taxation on the rise, the Forum provides an opportunity to keep abreast of developments in key jurisdictions around the world.
Using candid, seminar-style discussion, the group shares experiences and engages in meaningful dialogue on the most pressing issues they face.
Forum Co-Chairs:
• Michael J. Miller, Roberts & Holland LLP, United States
• Joseph Duffy, Matheson, Ireland
