Kostelanetz LLP

Criminalisation Of Tax Litigation And Development Of Negotiated Justice
2023-11-01 14:30 - 15:45 (Europe/Paris)
Caroline D. Ciraolo will participate in a panel titled “Criminalisation of tax litigation and development of negotiated justice” at the International Bar Association Annual Conference in Paris, France. The event takes place at the Amphitheatre Bordeaux on Wednesday November 1, 2023 from 8:30am – 9:45 am (ET) / 2:30pm – 3:45pm (CEST).
Event Description:
Tax violations assessed by the tax authorities may, in many cases, lead to criminal tax investigations. This growing trend in several European countries is the result of new measures aimed at criminalizing certain tax violations as well as of the action of the tax authorities to contrast tax evasion. The risk is not limited to manifest fraudulent cases (such as the issue of false invoices), but it may as well include less obvious cases such as the case of hidden permanent establishment or tax claims based on a certain interpretation of the law as the experience in several European countries has shown. In such cases, the managers of the involved companies may find themselves implied in criminal tax investigations or, in the worst case, charged with tax criminal convictions. With a practical approach focused on real cases, this panel will address the impact of criminal aspects from a tax perspective and discuss the available alternatives that can avoid criminal tax conviction or minimize the charges.
Session Chairs:
Francesco Capitta, Facchini Rossi Michelutti, Milan, Italy
Oliver Dauchez, Gide Loyrette Nouel A.A.R.P.I., Paris, France
Panelists:
Caroline D. Ciraolo, Kostelanetz LLP
Saravana Kumar, Rosli Dahlan Saravana Partnership, Kuala Lumpur, Malaysia
Prof. Dr. Wilhelm Haarmann, Frankfurt, Germany
Silvia Martina, Cagnola & Associati Studio Legale, Milan, Italy
Visit here for event details and here to register.

Criminal Tax Investigations and Procedures: What Practitioners Need to Know
2023-11-01 18:00 - 19:30 (America/New_York)
Megan L. Brackney and Stephen A. Josey will present on a webinar titled “Criminal Tax Investigations and Procedures: What Practitioners Need to Know” for the New York County Lawyers Association on November 1, 2023. CLE and CPE credit are offered for this event.
Event Description:
This course will provide foundational information about how federal criminal tax matters arise, how criminal tax matters are investigated, and other tips and best practices for dealing with clients who are (or may become) the subject of a criminal tax investigation.
Topics that will be covered include:

How federal criminal tax investigations originate, and the key government personnel involved in tax investigations and prosecutions;
Commonly investigated and prosecuted federal tax crimes, including statistics and elements of these crimes;
Investigatory techniques and tools used by the government in criminal tax matters;
Privileges that may apply between tax practitioners and their clients;
Situations where the tax practitioners, themselves, have criminal prosecution exposure;
Sentencing and post-trial proceedings.

Panelists:
Megan L. Brackney, Partner, Kostelanetz LLP
Stephen A. Josey, Counsel, Kostelanetz LLP
Click here to register and for more information

60th Annual Hawaii Tax Institute Conference
2023-11-05 - 2023-11-09
Caroline D. Ciraolo and Don Fort present on several panels at the 60th Annual Hawaii Tax Institute Conference in Honolulu, Hawaii on November 5-9. CLE credit is offered for this event.
Monday, November 6
4:00 pm – 4:45 pm (HST): Don Fort participates in a panel titled “Understanding the Sandbox that All Wealth Transfer Advisors Play In” on Monday, November 6 from 4:00 pm – 4:45 pm (HST) / 10:00 pm – 10:45 pm (EST).
Event Description:
The lines are drawn and all Wealth Transfer Advisors need to understand when “planning”
becomes a conspiracy or a crime. This session discusses the latest trends and updates on
Criminal Tax and the IRS’s Priorities, Cryptocurrency Updates and Developments, IRA 2023
Dirty Dozen, Impacts of the Inflation Reduction Act (IRA) on IRS operations and much more.
Panelists:
Don Fort, Director of Investigations, Kostelanetz LLP
Sandra R. Brown, Principal, Hochman Salkin Toscher Perez PC
Guy Ficco, Deputy Chief, IRS Criminal Investigation
Rebecca Perlmutter, Assistant U.S. Attorney
Tuesday, November 7
8:00 am – 9:00 am (HST): Caroline D. Ciraolo participates in a panel titled “Planning, Audit, and Litigation: Using Valuation Discounts to Transfer Wealth” on Tuesday, November 7 from 8:00 am – 9:00 am (HST) / 2:00 pm – 3:00 pm (EST).
Event Description:
Valuation Discounts are the essence of many wealth transfer strategies. This session discusses how valuation discounts are used in planning, what happens if challenged, and how courts evaluate the use of valuation discounts.
Panelists:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Carsten Hoffman, Managing Director, Stout
Andrew M. Katzenstein, Partner, Proskauer Rose
Patrick J. Urda, Judge, United States Tax Court
Wednesday, November 8:
1:30 pm – 2:20 pm (HST): Caroline D. Ciraolo participates in a panel titled “Left Holding the Bag: Withholding Agent Current Issues and Traps for the Unwary” on Wednesday, November 8 from 1:30 pm – 2:20 pm (HST) / 7:30 pm – 8:20 pm (ET).
Event Description:
The global marketplace and increased individual mobility has created additional scenarios where U.S. taxpayers are sending payments outside the United States, thereby making them subject to U.S. withholding and reporting requirements. IRS LB&I has a compliance campaign to examine taxpayers who make such payments but fail to meet their compliance obligations. This session will identify the subset of taxpayers (withholding agents) who are responsible for withholding U.S. tax on payments to foreign payees, explain the surprising way withholding agents can become liable for tax due on money paid to others, and describe how the IRS is holding U.S. withholding agents accountable for the tax liabilities of foreign payees.
Panelists:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Kurt K. Kawafuchi, Managing Member, Law Offices of Kurt Kawafuchi, LLC
Michael Quigley, Partner, Kim & Chang
Thursday, November 9
11:30 am – 12:15 pm (HST): Don Fort participates in a panel titled “Employee Retention Credit Audits and Investigations – The Tsunami is Coming” on Thursday, November 9 from 11:30 am – 12:15 pm (HST) / 5:30 pm – 6:15 pm (EST).
Event Description:
Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. Almost
everyone has seen a commercial or received a text or email offering easy money through
ERC claims. With its inclusion of erroneous and fraudulent ERCs in the IRS’s 2023 list of
“Dirty Dozen” schemes, the IRS has made no secret of its plans to aggressively audit ERC
claims and punish abuse and fraud. This session will discuss the IRS’ targeted enforcement
efforts, explains how to spot red flags indicating abuse of the ERC, and describe the civil
and criminal penalties that can apply to taxpayers, promoters and practitioners for erroneously
claiming ERC credits.
Panelists:
Don Fort, Director of Investigations, Kostelanetz LLP
Sandra R. Brown, Principal, Hochman Salkin Toscher Perez PC
Kathy Enstrom, Director of Investigations, Moore Tax Law Group LLC
Victor S.O. Song, Former Chief, IRS Criminal Tax Division

Visit here for event details and here to register.

Forms 5471 and 5472: Meeting the Substantially Complete Standards
2023-11-06 13:00 - 15:00 (America/New_York)
Michael Sardar presents on a webinar titled “Forms 5471 and 5472: Meeting the Substantially Complete Standards” for Strafford on November 6, 2023. CPE credit is offered for this event.
Event Description:
This course will discuss best practices for meeting the substantially complete standard for international reporting required for Forms 5471 and 5472 and as applied to other required foreign information returns.
Forms 5471 and 5472 are two of the most complex foreign information reporting forms completed by tax practitioners. Whether by oversight or newly acquired information, these forms are often incomplete or incorrect when submitted. Errors may include the omission of a country or transaction on Form 5472, the category may be omitted on page one, or a taxpayer may use an accounting method other than GAAP used on Form 5471.
Since the criteria for substantial compliance is a facts and circumstances determination, any number of problems could deem a foreign information return not substantially complete and not meeting the information reporting requirements of Sections 6038 or 6038A. The penalties for not meeting these reporting requirements are steep–$10,000 per month to a maximum of $50,000 if not timely resolved.
The penalty abatement process for these filings is challenging. Tax practitioners working with international clients need to understand the threshold for substantial compliance for these cumbersome international reporting forms.
Panelists:
Michael Sardar, Partner, Kostelanetz LLP
John Samtoy, Tax Partner, Holthouse Carlin & Van Trigt LLP
Click here to register and for more information

Planning, Audit, And Litigation: Using Valuation Discounts To Transfer Wealth
2023-11-07 08:00 - 09:00 (Pacific/Honolulu)
Caroline D. Ciraolo will participate in a panel titled “Planning, Audit, and Litigation: Using Valuation Discounts to Transfer Wealth” at the 60th Annual Hawaii Tax Institute in Honolulu, Hawaii. The panel takes place at the Sheraton Waikiki Resort on Tuesday, November 7 from 8:00am – 9:00 am (HST) / 2:00pm – 3:00pm (ET).
Event Description:
Valuation Discounts are the essence of many wealth transfer strategies. This session will discuss how valuation discounts are used in planning, what happens if challenged, and how courts evaluate the use of valuation discounts.
Panelists:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Carsten Hoffman, Managing Director, Stout
Andrew M. Katzenstein, Partner, Proskauer Rose
Patrick J. Urda, Judge, United States Tax Court
Visit here for event details and here to register.

Not Just Asking: IRS Audits in Theory and Practice
2023-11-07 12:45 - 14:25 (America/New_York)
Jay R. Nanavati and Andrew Weiner present on a panel at the Maryland Association of CPAs 2023 Advanced Tax Institute on November 7, 2023.
Event Description:
This panel demystifies the audit process and prepares you for the next time your client receives a dreaded IRS audit letter. You will learn how the IRS selects returns for audit, what to expect and how to advise clients. You will also learn the warning signs that a civil audit may be headed in the direction of a criminal investigation and how to guard against the possibility. Finally, you will see how the process works in practice by focusing on IRS examinations of Malta pension plans, one of the current “Dirty Dozen” tax scams that are enforcement priorities.
Featured Speakers:
Jay R. Nanavati, Kostelanetz LLP
Andrew Weiner, Kostelanetz LLP
Please visit here to register and for more information.

Left Holding the Bag: Withholding Agent Current Issues And Traps For The Unwary
2023-11-08 14:30 - 15:30 (Pacific/Honolulu)
Caroline D. Ciraolo will participate in a panel titled “Left Holding the Bag: Withholding Agent Current Issues and Traps for the Unwary” at the 60th Annual Hawaii Tax Institute in Honolulu, Hawaii. The panel takes place at the Sheraton Waikiki Resort on Wednesday, November 8 from 1:30pm – 2:20pm (HST) / 7:30pm – 8:20pm (ET).
Event Description:
The global marketplace and increased individual mobility has created additional scenarios where U.S. taxpayers are sending payments outside the United States, thereby making them subject to U.S. withholding and reporting requirements. IRS LB&I has a compliance campaign to examine taxpayers who make such payments but fail to meet their compliance obligations. This session will identify the subset of taxpayers (withholding agents) who are responsible for withholding U.S. tax on payments to foreign payees, explain the surprising way withholding agents can become liable for tax due on money paid to others, and describe how the IRS is holding U.S. withholding agents accountable for the tax liabilities of foreign payees.
Panelists:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Kurt K. Kawafuchi, Managing Member, Law Offices of Kurt Kawafuchi, LLC
Michael Quigley, Partner, Kim & Chang
Visit here for event details and here to register.

Confessions Of A Tax Cheat: Using The Voluntary Disclosure Practice To Bring Taxpayers Back Into Compliance
2023-11-08 15:20 - 17:00 (America/Chicago)
Michael Sardar will present “Confessions of a Tax Cheat: Using the Voluntary Disclosure Practice to Bring Taxpayers Back into Compliance” at the American Society of Tax Problem Solvers Super Conference 2023 on November 8th, 2023. The conference will be held both in-person and virtually. The events are hosted at the Hilton Dallas/Southlake in Dallas, TX.
Event Description:
Navigating the complexities of tax compliance can be challenging, especially for those who have previously deviated from their obligations. The IRS’s voluntary disclosure practice serves as a beacon of hope, offering a structured route for such taxpayers to rectify their past noncompliance and return to full compliance.
This course delves deep into the IRS’s voluntary disclosure practice, which is designed for individuals whose actions were willful, fraudulent, or even criminal. By leveraging the IRS’s voluntary disclosure practice, taxpayers can shield themselves from potential criminal prosecution and significantly reduce the civil penalties that might otherwise be levied against them.

Click here for more information.

What Would OPR Do? – Ethically Advising a Tax Non-Compliant Client (CLE)
2023-11-08 15:30 - 17:00 (America/New_York)
Megan L. Brackney will be a featured speaker in a program titled “What Would OPR Do? – Ethically Advising a Tax Non-Compliant Client” at the 2023 Tax Section Annual Meeting and CLE on November 8th, 2023. The conference will be held both in-person and virtually. The events are hosted at the Philadelphia Marriott Downtown in Philadelphia, PA.
Featured Speakers:
Megan L. Brackney, Partner, Kostelanetz LLP
Melissa L. Wiley, Partner, Lowenstein Sandler LLP

CLE Credit is available for attendance.
Please visit here for registration details and the program overview.

When Ethics And The Art Lawyer Meet (CLE)
2023-11-10 11:00 - 12:15 (America/New_York)
Megan L. Brackney will participate in a panel titled “When Ethics And The Art Lawyer Meet” at the Appraisers Association of America’s 2023 Art Law Day Program on November 10th, 2023. The conference will be held both in-person and virtually. The events are hosted at the Benjamin Cardozo School of Law in New York, NY.
Panel Moderator:
Steve Schindler, Partner, Schindler Cohen & Hochman LLP
Panelists:
Megan L. Brackney, Partner, Kostelanetz LLP
Michael S. Ross, Principal, Law Office of Michael S. Ross

CLE Credit is available for in-person attendance.
Registration begins on August 30th, 2023. Please visit here for registration details. Please visit the program guide for more information.

When To Call A Lawyer Before You Need A Lawyer: Privilege, Practice And Procedure (CPE)
2023-11-13 16:20 - 17:35 (America/New_York)
Caroline D. Ciraolo will present “When to Call a Lawyer Before you Need a Lawyer: Privilege, Practice and Procedure” at the 2023 AICPA & CIMA National Tax & Sophisticated Tax Conference on November 13th, 2023. The conference will be held both in-person and virtually. The events are hosted at the Omni Shoreham Hotel in Washington, DC.
Event Description:
In representing clients in tax matters, it is critical that accountants and other tax professionals know what privileges may apply, when those privileges apply, who holds the privilege, how and when a privilege is invoked, the ramifications of invoking privilege, exceptions to a privilege, and the facts and circumstances that may waive a privilege. Because certain privileges are reserved to communications with or services rendered by lawyers, other tax professionals need to know when a client should be referred to counsel. This presentation will address these issues and provide practical, real-world examples and best practices.
CPE Credits are available for this event.
Registration for onsite and online attendance remains open. Please visit here for registration details. Please visit the program guide for more information.

Puerto Rico Tax Strategies: Acts 20/22/60 (CPE)
2023-11-14 15:15 - 16:00 (America/New_York)
Jay Nanavati presented “Puerto Rico Tax Strategies: Acts 20/22/60” at the 2023 AICPA & CIMA National Tax & Sophisticated Tax Conference on November 14th, 2023. The conference was held both in-person and virtually. The events were hosted at the Omni Shoreham Hotel in Washington, DC.
Event Description:
This session will dive into the top 10 things to know if your U.S. client moves, or is contemplating a move, to Puerto Rico.
Learning Objectives:

Identify and be able to apply the test for qualifying as a bona fide resident of Puerto Rico and the relevant income source rules.
Recall the context and current status of the IRS’ ongoing Puerto Rico-focused compliance campaign.

CPE Credits were available for this event.
Please visit here for program details. Please visit the program guide for more information.

2023 PACDL White Collar Practice Seminar (CLE)
2023-11-16 13:45 - 14:45 (America/New_York)
Sharon L. McCarthy participates in a panel titled “Old Rule? No Problem. Rule 16 is Officially Revamped for Expert Witnesses” hosted by the Pennsylvania Association of Criminal Defense Lawyers at 1:45 pm EST on November 16, 2023. CLE credit is offered for this event.
Event Description:
In this session, the panelists discuss former Rule 16(a)(1)(G) and the problems prompting change. Before now, the government only needed to provide a summary to the defense. Under the new rule, the government must disclose more and the defense now has plenty to work with. The catch? Both sides must disclose and both sides have more to work with. Panelists discuss the benefits of the changes and nuances to be aware of moving forward.
Moderator:
Caroline G. Donato, Partner, MacElree Harvey, Ltd.
Speakers:
Sharon L. McCarthy, Partner, Kostelanetz LLP
Michael Comber, Partner, Comber Miller LLC
Click here to register and click here for the program guide.

Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know
2023-11-17 13:15 - 14:15 (America/Chicago)
Andrew M. Weiner will participate in a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” at the Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2023 Chicago Conference hosted by the Practising Law Institute on Nov. 15-17, 2023. The conference will be held both in-person and virtually.
Event Description:
This panel will focus on the various judicial doctrines and ethical issues that arise in the corporate tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on corporate transactions, including standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions
Respond to the IRS in an audit

Panelists:
Andrew M. Weiner, Counsel, Kostelanetz LLP, New York, NY
Bradley M. Seltzer, Partner, Holland & Knight, Santa Ana, CA
CLE Credit is available for this event.
Visit here for registration and event details.

Convergence of AML And Fraud Controls: Thinking Through Opportunities And Obstacles In A FRAML Approach
2023-11-30 08:30 - 10:00 (America/New_York)
John D. Fort will present “Convergence of AML and Fraud Controls. Thinking through opportunities and obstacles in a FRAML approach” at the American Bankers Association / American Bar Association Financial Crimes Enforcement Conference on November 30th, 2023. The conference will be held both in-person and virtually. The events are hosted at the Gaylord National Resort and Convention Center in National Harbor, MD.
Event Description:
Managing a fraud program in the current environment can be challenging. Many banks have separate fraud and AML teams and even separate databases and alert cycles – but is this the most efficient and effective way to protect the bank and customers? Join us as we explore opportunities, identify synergies and efficiencies that come from a holistic strategy that combines both fraud and AML prevention, controls, and compliance. FRAML and being open to transformation may be how you can better position your institution to counter escalating risks.
Moderator:
Marilu Jimenez, Chief Compliance Officer, Nave Bank
Speakers:
Don Fort, Director of Investigations, Kostelanetz & Fink, LLP
Michael J. Leotta, Partner, WilmerHale
Tyler E. Reynolds, Enterprise Financial Crimes Executive, AML/BSA Officer, U. S. Bank
William J. Voorhees, Senior Vice President, Head of Enterprise Fraud Management, Truist
Click here for more information.

Kostelanetz Hosts Watch Party For Alum's Oral Argument At Harvard Ames Moot Court Final Round
2023-11-30 12:00 - 13:00 (America/New_York)
On November 30, 2023, over 25 Kostelanetz employees gathered to watch Daniel Flesch (Kostelanetz Pre-Law Paralegal Class of 2021) present oral argument to Honorable Sonia Sotomayor (United States Supreme Court), Goodwin Liu (Supreme Court of California), and Rachel Kovner (United States District Court for the Eastern District of New York) at the Harvard Ames Moot Court Final Competition. Daniel and his Ames teammate, Phoebe Kotlikoff, joined the watch party to talk about their Ames Moot Court experiences.
The Harvard Ames Moot Court Competition, first established in 1911, is one of the most distinguished and intense competitions for appellate brief writing and advocacy. After multiple rounds of competitions in the 2022-2023 academic year, Daniel and his team advanced to the final round. Daniel’s team, called the Patsy Takemoto Mink Memorial Team (Petitioner), consisted of Derek Choi, Kunal Dixit, Phoebe Kotlikoff, Yusuke Tsuzuki, and Monica Wang.
During the Q&A, we asked Daniel and Phoebe to tell us more about the Ames experience:
Jackie Sideris, a senior paralegal at the firm, asked Daniel and Phoebe how Ames Moot Court is similar to and different from other oral advocacy competitions, like mock trial and debate.
Sharon L. McCarthy, a partner at Kostelanetz, reflected on how impressive it was that Daniel had chosen to argue without looking at prepared notes. Daniel explained that he intentionally responded to the judges’ questions without relying on his notes in order to maintain eye contact with the judges.
Jay R. Nanavati, another partner at Kostelanetz, likewise applauded Daniel and his teammates for their hard work and noted that the oral advocacy skills they demonstrated are precisely those needed to succeed in the legal profession.
Event moderator and paralegal Tiffany Jing remarked that the watch party was a great learning experience for the Pre-Law Paralegals, as they prepare for their futures in law school.
In her feedback to the competitors, Honorable Justice Sotomayor commended, “watching the skill of all of you, for me, is inspiring.” We, at Kostelanetz, were likewise inspired by the work and performance of Daniel and his teammates in the Ames final round.
Click here for more information. Click here to watch the full competition recording.

Enforcement Trends: What’s Hot and What’s Not
2023-12-01 10:15 - 11:05 (America/New_York)
Megan L. Brackney will moderate a panel titled “Enforcement Trends: What’s Hot and What’s Not” at the 2023 IRS Representation Conference on December 1st, 2023. The conference will be held both in-person and virtually. The events are hosted at the Mohegan Sun Hotel & Casino, CT and by the Quinnipiac University School of Law in North Haven, CT.
Event Description:
Following the Covid pandemic and the programs instituted by Congress we are about to enter a new era of tax enforcement, including Employee Retention Credits, Payroll Tax Debts, and much more. Join our panelists for a discussion of the changing tax enforcement landscape as it relates to examinations, collection and criminal investigations.
Panel Moderator:
Megan Brackney, Esq., Kostelanetz LLP, New York, NY
Panelists:
Daniel Mayo, Esq., Withum, Smith & Brown, PC, Red Bank, NJ
Michelle F. Schwerin, CPA, JD, Capes, Sokol, Goodman & Sarachan, PC, St. Louis, MO
Barbara T. Kaplan, Esq., Greenberg Traurig LLP, New York, NY
Registration for in-person attendance has closed. Registration for webcast attendance remains open. Please visit here for registration details. Please visit the program guide for more information.

Form 5471 Substantial Compliance Rules: IRS International Practice Unit Guidance, Pitfalls To Avoid (CLE / CPE)
2023-12-05 13:00 - 14:30 (America/New_York)
Michael Sardar will present “Form 5471 Substantial Compliance Rules: IRS International Practice Unit Guidance, Pitfalls To Avoid” at Strafford on December 5, 2023. The webinar will be held virtually.
CLE / CPE credit is offered for this event.
Event Description:
This CLE/CPE course will provide tax counsel and advisers with a practical discussion of IRS International Practice Unit (IPU) guidance on what constitutes “substantial compliance” in filing Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations. The panel will detail the IRS guidance on applying the substantial compliance doctrine and the meaning of “substantially complete” for purposes of the Service’s imposition of penalties related to international information return requirements.
Benefits:
The panel will review these and other highly relevant concepts:

IRC 6038 information reporting requirements and penalties
Guidance on Category 4 vs. Category 5 filers
How the IPU advises examiners to view substantial compliance in light of tax court holdings and prior IRS advice
Errors “beyond the face” of Form 5471 that will cause an examiner to treat the filing as not substantially complete
Common errors on Form 5471 that render the filing to be not substantially complete

Speakers:
Michael Sardar, Partner, Kostelanetz LLP
John Samtoy, Tax Partner, Holthouse Carlin & Van Trigt
Click here for more information.

40th Annual National Institute on Criminal Tax Fraud and the 13th Annual National Institute on Tax Controversy
2023-12-07 - 2023-12-09
Kostelanetz attorneys will participate in a variety of panels and presentations at the 40th Annual National Institute on Criminal Tax Fraud and the 13th Annual National Institute on Tax Controversy in Las Vegas, NV on December 7-9, 2023.
Thursday, December 7, 2023
2:30 pm – 5:00 pm (PST): Michael Sardar presents on a panel titled “Criminal Tax Workshop.”
Description: The Criminal Tax Workshop will cover the “nuts and bolts” of a criminal tax investigation
through resolution. We will address strategies and techniques for handling sensitive civil
examinations and criminal investigations, and defending a criminal prosecution, including
relevant evidence, 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.
Learning Objectives:
• When to anticipate a criminal referral
• Representing a client through the process and procedures of a criminal investigation
• Considering opportunities for advocacy at each stage of the investigation and preprosecution
• Understanding pre-trial and trial issues
• Taking advantage of strategic opportunities
Co-Moderators:

Michelle Feit Schwerin, Shareholder, Neill Schwerin Boxerman, P.C.
Justin Gelfand, Partner, Margulis Gelfand, LLC

Panelists:

Michael Sardar, Partner, Kostelanetz LLP
Caryn Finley, Assistant US Attorney
Elizabeth Hadden, Deputy Associate Chief Counsel, IRS Criminal Tax
Edward Robbins, Jr., Principal, Hochman Salkin Toscher Perez, P.C.
Richard Speier, Former Deputy Chief, IRS CI
Jeff Trevillion, Jr., Director, Crowe & Dunlevy, P.C.

Friday, December 8, 2023
10:30 am – 11:30 am (PST): Megan L. Brackney moderates a panel titled “Criminal Enforcement Priorities.”
Description: Hear a roundtable discussion of hot topics, recent decisions, and enforcement priorities in
criminal tax enforcement. The speakers are all current or former Internal Revenue Service or
Department of Justice leaders and prosecutors.
Learning Objectives:
• To provide information about IRS Criminal Investigation’s top enforcement priorities.
• To provide information about recent criminal tax cases.
• To provide an overview of areas of concern for the IRS, including Malta pension plans
and syndicated conservation easement transactions, and the IRS’s criminal enforcement
focus on these transactions.
• To discuss recent developments in the U.S. Sentencing Guidelines and how that might
impact the work of CI.
Moderator: Megan L. Brackney, Partner, Kostelanetz LLP
Panelists:

Guy Ficco, Deputy Chief, IRS Criminal Investigation
Richard T. Lunger, Deputy Division Counsel (Criminal Tax), Office of Chief Counsel, IRS
Rod J. Rosenstein, Partner, King & Spalding LLP

11:30 am – 12:30 pm (PST): Bryan C. Skarlatos moderates a panel titled “When You Know Something That The Government Does Not: Ethical Considerations In Keeping Your Civil Case From Going Criminal.”
Moderator: Bryan C. Skarlatos, Partner, Kostelanetz LLP
Panelists:

Jeffery Neiman, Partner, Marcus Neiman & Rashbaum LLP
Josh Ungerman, Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman LLP
Zhanna Ziering, Member, Moore Tax Law Group LLC

2:45 pm – 3:45 pm (PST): Don Fort co-moderates a panel titled “Tax Enforcement Across Generations: Senior IRS Special Agents In Dialogue With Those Who Follow In Their Footsteps.”
Description: Understand how tax enforcement strategies, agent capabilities, and prosecuted cases have
evolved over 20 years through a dialogue between senior and new IRS special agents. Recognize
how the proliferation of digital data and analytical tools has impacted evidence gathering and
prosecutions. Appreciate how the IRS has adapted techniques to uncover complex global tax
avoidance. Gain insight on current enforcement priorities, challenges, and knowledge sharing
from direct experiences of senior and new special agents.
Learning Objectives:
• Gain perspective on how tax enforcement strategies have evolved over the past 20 years
based on insights from senior and new IRS agents.
• Understand how the proliferation of digital evidence has impacted IRS special agents’
investigative approaches and techniques.
• Recognize the value of knowledge sharing between senior and new IRS special agents to
enhance overall enforcement capabilities.
Co-Moderators:

Don Fort, Director of Investigations, Kostelanetz LLP
Frank Agostino, President, Agostino & Associates PC

Panelists:

Panel of current and retired IRS Special Agents TBA

5:00 pm – 6:00 pm (PST): Caroline D. Ciraolo moderates a plenary session titled “How To Mentor Across Differences And Build A More Effective Tax Practice Through Diversity.”
Description: A recent McKinsey & Company study found that companies with diverse executives were 36%
more likely to report above-average profits. Moreover, diversity, equity, and inclusion in law
firms lead to increased critical thinking and advocacy skills, attract larger clients, and spurs
economic growth. Nonetheless, there has been a historical lack of diversity in tax practices
across the country. Recognizing this gap, tax professionals are striving to diversify their
organizations, and while there are methods – often financially driven – to recruit diverse
professionals, retaining those same professionals and building the next generation of diverse
leaders can be a challenge. The panelists will discuss how they and their respective organizations
are mentoring across differences to recruit, retain, and promote diverse practitioners and, in
doing so, build a more effective tax practice.
Learning Objectives:
• Understanding the benefits of diversity in the legal profession
• Understanding various types of diversity in the legal profession and obstacles faced by
diverse practitioners
• Identifying ways to cultivate sponsorships and mentorships for diverse practitioners
• Identifying ways to structure training and education on interrupting implicit bias and
other roadblocks
• Identifying ways to obtain and respond to meaningful feedback on DEI efforts
Moderator: Caroline D. Ciraolo, Partner, Kostelanetz LLP
Panelists:

David Farhat, Partner, Skadden, Arps, Slate, Meagher & Flom LLP
Carlos Ortiz, Partner, BakerHostetler LLP
Melissa Wiley, Partner, Lowenstein Sandler LLP

Click here to register and for more information.

2024 D.C. Bar Tax Conference: "Partnership Taxation/ Tax Controversy: BBA Partnership Audits in a Post-IRA World"
2024-01-10 14:15 - 15:30 (America/New_York)
Kostelanetz counsel Andrew Weiner will participate in the 2024 D.C. Bar Tax Conference on the panel entitled “Partnership Taxation/ Tax Controversy: BBA Partnership Audits in a Post-IRA World” on January 10, 2024.
Date and Time:
Wednesday, January 10, 2024, 2:15 pm – 3:30 pm (Eastern)
Description:
The IRS is using the significant funding it received under the Inflation Reduction Act of 2021 to increase audits of wealthy individuals and large businesses, including partnerships. Panelists will discuss what taxpayers and practitioners can expect under the BBA partnership audit regime and provide tips for navigating this brave new world.
Speakers:
•Rochelle Hodes, Principal, Crowe LLP
•Mary Slonina, Managing Director, KPMG LLP
•Andy Weiner, Counsel, Kostelanetz LLP
•Clifford Scherwinski, Director, Pass-Through Entities Practice Area, Large Business & International, Internal Revenue Service
•Jennifer Black, Senior Counsel, Internal Revenue Service
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Tax Litigation Update Including Recent Decisions And Their Impact On Corporate And Individual Taxpayers
2024-01-11 10:30 - 11:45 (America/New_York)
Caroline Ciraolo will speak in a panel titled “Tax Litigation Update Including Recent Decisions and Their Impact on Corporate and Individual Taxpayers” at the 2024 D.C. Bar Annual Tax Conference on January 11, 2024. The conference will take place at D.C. Bar headquarters with a virtual option.
Event Description:
Leading tax practitioners will discuss recent tax litigation decisions, and the impact of these decisions on individual and corporate clients in the tax litigation space. Kostelanetz LLP Partner Caroline D. Ciraolo will be contributing to the discussion.
Hosted by the Tax Community at the 2024 D.C. Bar Annual Tax Conference.
Moderator:
Michael Desmond, Partner, Gibson, Dunn & Crutcher LLP
Panelists:
• Caroline Ciraolo, Partner, Kostelanetz LLP and Adjunct Professor of Law, The Georgetown University Law Center
• Andrew Strelka, Counsel, Latham & Watkins, LLP
• Lindsay L. Clayton, Assistant Chief, Tax Division, U.S. Department of Justice
• Justin L. Campolieta, Special Trial Attorney (Senior Level), IRS Office of Chief Counsel, Strategic Litigation
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Navigating Between Tax Litigation And Other Dispute Resolution Mechanisms
2024-01-16 16:15 - 17:15 (America/New_York)
Caroline Ciraolo will speak in a panel titled “Navigating Between Tax Litigation And Other Dispute Resolution Mechanisms” at the 13th Annual London Finance and Capital Markets Conference on January 16, 2024. The conference is hosted by the International Bar Association at One Great George Street, London, England.
Event Description:
This event will cover the following subjects:

An assessment of the reliability of the domestic tax litigation
The impact of criminal tax exposure on the civil case
Group policy relating to tax disputes
Are mutual agreement procedures (MAPs) and arbitration always viable alternatives?
Which tax issues generate most disputes in addition to transfer pricing?
Pro and cons of tax settlements including creditability of the settled tax in the home state

Chair:
Guglielmo Maisto, Maisto & Associates, Milan, Italy
Panelists:
Ramona Azzopardi, WH Partners, Ta Xbiex, Malta
Caroline Ciraolo, Kostelanetz LLP, Washington, DC, USA
Michel Collet, CMS Francis Lefebvre Avocats, Neuilly-sur-Siene, France
Gregory Price, Macfarlanes LLP, London, England
Sonja Schiller, Google, Seattle, Washington, USA
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American Bar Association Tax Section 2024 Midyear Tax Meeting
2024-01-18 - 2024-01-20
Kostelanetz attorneys will participate in a variety of panels and presentations at the American Bar Association Tax Section’s 2024 Midyear Tax Meeting in San Francisco, CA on January 18-20, 2024.
Thursday, January 18, 2024
1:30 PM – 2:30 PM (PST): Andrew Weiner participates in a panel titled “Equitable Tolling and Tax Collections.”
Description: This panel will focus on equitable tolling and how it applies to requests for collection due process hearings and in the Tax Court.
Moderator:
Goldburn P. Maynard, Jr., Loretta Argrett Fellow, Assistant Professor, Indiana University, Kelley School of Business
Panelists:
Andrew Weiner, Counsel, Kostelanetz LLP
Jonathan Kalinski, Shareholder, Hochman, Salkin, Toscher, Perez P.C.
Christopher Jones, Senior Technician Reviewer, Procedure & Administration (Branch 4), IRS Office of Chief Counsel
2:00 pm – 3:00 pm (PST): Michael Waalkes participates in a panel titled “Employee Retention Credits: Overview and Audit Risks”
Description: This panel will provide an overview of the background and evolution of the “employee retention credits,” first introduced with the CARES Act. Panelists will address recent IRS announcements acknowledging potentially fraudulent employee retention credit schemes and erroneous claims for such refunds, and the impact of heightened audit risks for companies, including in M&A transactions.
Panelists:
Michael Waalkes, Associate, Kostelanetz LLP
Greg A. Chriss, PwC U.S. Tax LLP
Jimmy B. Franco, Indirect Tax Manager, Ernst & Young LLP
Andrew L. Gradman, Partner, Falcon Rappaport & Berkman LLP
Rami M. Khoury, Associate, Taylor Nelson Amitrano LLP
6:00 PM – 7:30 PM (PST): Michael Waalkes participates in a panel titled “Careers in Tax.”
Description: This panel will open a discussion between current practitioners in the tax law space to provide information for L.L.M. or J.D. students seeking a career in tax.
Moderator:
Janelle N. Darnell, Associate, McGuireWoods LLP
Panelists:
Michael Waalkes, Associate, Kostelanetz LLP
Marc D. Nickel, Associate, McGuireWoods LLP
Sean Silva, M&A Tax Sr. Manager, KPMG LLP
Lany L. Villalobos, Associate, Kirkland & Ellis LLP
Friday, January 19, 2024
4:00 PM – 4:55 PM (PST): Andrew Weiner participates in a panel titled “Defining Refund Litigation When the Refund Claim is Filed.”
Description: Refund litigation is likely to increase as the IRS summarily denies refund claims through its Service Centers or plainly refuses to process other types of refund claims, such as those involving the employee retention credit. The scope of the refund litigation is defined when the refund claim is administratively filed with the IRS. The panelists will discuss best practices for filing administrative refund claims, including how to navigate: statutes of limitation considerations; the specificity requirements; the doctrine of variance; protective claims for refund; and more.
Moderator:
Garrett L. Brodeur, Associate, Skadden, Arps, Slate, Meagher & Flom LLP
Panelists:
Andrew Weiner, Counsel, Kostelanetz LLP
Pamela Grewal, Managing Director, Andersen
Christopher Jones, Senior Technician Reviewer, Procedure & Administration (Branch 4), IRS Office of Chief Counsel
Saturday, January 20, 2024
9:30 AM – 10:30 AM (PST): Maxwell Brown participates in a panel titled “Strategical Issues in the Evolving ERC Area.”
Description: Panel will discuss the moratorium and strategical issues taxpayers should consider moving forward in an uncertain enforcement environment.
Moderator:
Mary Wood, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
Panelists:
Maxwell Brown, Associate, Kostelanetz LLP
Tony Box, Partner, Gray Reed
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Employee Retention Credits: Overview And Audit Risks
2024-01-18 14:00 - 15:00 (America/Chicago)
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Careers in Tax
2024-01-18 18:00 - 19:30 (America/Chicago)

Where In The World...? Recent Updates In International Information Return Caselaw And Practice
2024-01-24 12:30 - 13:30 (America/New_York)
Heather Fincher will participate in a panel titled “Where in the World…? Recent Updates in International Information Return Caselaw and Practice” hosted by the D.C. Bar on January 24, 2024. The conference will be held virtually.
Event Description:
Tax controversy professionals – including the current National Taxpayer Advocate – have been bemoaning the complex filing requirements and onerous penalties associated with international information return penalties for years. No longer limited to the notorious FBAR, since before COVID, the IRS has been cracking down on international information reporting forms such as Forms 5471, 5472, 3520, and 3520-A. Appeals has been overrun with cases challenging international information return penalties on the grounds of reasonable cause. This past year, it was the courts’ turn to chime in.
This panel will explore the recent string of international information reporting cases (including Fahry, Aroeste, and Bittner) and discuss their implications for the future. Attendees are encouraged to come with their own war stories, tips, tricks and questions!
Pre-registration for this program is required. As always, please feel free to share this invitation with colleagues. D.C. Bar membership is not required to attend. Non-members will need to create a profile to register and access the content.
Sponsored by: Tax Audits and Litigation Committee of the D.C. Bar Taxation Community
Speakers:
Heather Fincher, Associate, Kostelanetz LLP
Pedro Corona de la Fuente, Partner, Procopio, Cory, Hargreaves & Savitch LLP
Victor Jaramillo, Member, Caplin & Drysdale, Chartered
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Industry Development Series: Financial Crime Enforcement Across Borders
2024-02-22 08:30 - 17:00 (America/New_York)
On February 22, 2024, Kostelanetz LLP, AlixPartners, and the Bahamas Financial Services Board will host a seminar on “Financial Crime Enforcement Across Borders” for financial industry professionals in Nassau, Bahamas. Caroline D. Ciraolo and Jay R. Nanavati will be featured speakers.
Panel topics will include:

Bahamas Regulatory Update
Cross-Border Criminal Tax Update
AML & OFAC/Sanctions Enforcement Update
The DOJ’s Emphasis on Individual Liability for Corporate Crime
Developing and Implementing an Effective Risk Management Program
Combatting Financial Crime in the Digital Assets Fintech Space

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Federal Bar Association 2024 Tax Law Conference (CLE/CPE)
2024-03-01 08:00 - 2024-03-05 17:00 (America/New_York)
Join the Section on Taxation for the 48th Annual Tax Law Conference. This three-day program will offer the same great content in-person and online. Programming will be held in-person on Friday, March 1 and virtually from Monday, March 4 – Tuesday, March 5. Programming will include a keynote luncheon address and awards reception for the prestigious Kenneth H. Liles Award for Distinguished Service to an eminent tax practitioner. Ethics, CLE, and CPE credit will be available.
Friday, March 1, 2024
4:00 PM – 5:00 P.M. (EST): Megan L. Brackney participates in a panel titled “Multijurisdictional Ethics Issues – Working in Multiple Jurisdictions – Some Things You May Not Think About May Hurt.”
Description: Practitioners who represent foreign (and domestic) clients face problems that not only raise ethics issues (like practicing in more than one jurisdiction – e.g., license issues, language issues, as well as knowledge of other jurisdictions), but importantly may also involve them and their clients in a number of reporting requirements and even scrutiny under federal money laundering and other statutes that impose criminal liability. These situations require thought about due diligence on accepting clients from other jurisdictions who may have needs or motives besides having a house in your state – tax evasion, reporting of income and assets, etc. This panel will discuss matters you really need to consider and actions you need to take to represent clients with more complex investments and businesses.
Moderator:
Fred Murray, Special Counsel, IRS, U.S. Department of the Treasury
Panelists:
Megan L. Brackney, Partner, Kostelanetz LLP
Matt Cooper, Managing Director, Tax Controversy Services, Deloitte Tax LLP
Emily Lesniak, Senior Level Counsel, Procedure and Administration, IRS, U.S. Department of the Treasury
Monday, March 4, 2024
12:30 PM – 1:30 PM (EST): Michael Sardar moderates a panel titled “The Employee Retention Credit Rewind: Evaluating ERC Claims and Determining the Right Path Forward.”
Description: The Employee Retention Credit (“ERC”) is a pandemic-era program that allowed taxpayers who suffered a pandemic-related business interruption to claim a tax credit tied to the number of employees employed by the business. Only businesses that met certain qualification guidelines were entitled to claim benefits under the ERC. In the midst of the pandemic-driven rush to distribute funds to taxpayers, some taxpayers made ERC claims that did not meet Congress’ qualification criteria. The Service has stepped-up enforcement efforts with respect to nonqualifying claims by auditing taxpayer ERC claims, investigating tax advisors and ERC consulting companies, and taking other enforcement action. The IRS has also paused processing new ERC claims, instituted a withdrawal program that would allow certain taxpayers to withdraw nonqualifying claims, and announced a voluntary disclosure program to allow taxpayers to return inappropriately claimed ERC funds.
Moderator:
Michael Sardar, Partner, Kostelanetz LLP
Panelists:
Melissa Henkel, Branch Chief, Office of Chief Counsel, IRS, U.S. Department of the Treasury
Starling Marshall, Partner, Crowell & Moring LLP
John McInelly, Executive Lead, Employee Retention Credit, IRS, U.S. Department of the Treasury
Daniel Strickland, Senior Counsel, Holland & Knight
2:00 PM – 3:00 PM (EST): Caroline D. Ciraolo moderates a panel titled “Defending Malta Pension Plans – Lessons Learned and What Lays Ahead….”
Description: In July 2021, the IRS added Malta pension plans (MPPs) to its “Dirty Dozen” list as a “potentially abusive” transaction, explaining that some “U.S. citizens and residents are relying on an interpretation of the U.S.‐Malta Income Tax Treaty (Treaty) to take the position that they may contribute appreciated property tax free to certain Maltese pension plans and that there are also no tax consequences when the plan sells the assets and distributes proceeds to the U.S. taxpayer. In December 2021, the IRS announced a Competent Authority Arrangement between the U.S. and Malta stating the mutual understanding that “pension fund” for purposes of the Treaty does not include a plan that allows participants to contribute property other than cash or does not limit contributions based on a taxpayer’s employment or self-employment income. On June 7, 2023, the IRS proposed making the MPPs a listed transaction, and later that month, IRS Criminal Investigation issued numerous summonses to individuals and entities involved in MPPs and later confirmed a joint investigation with IRS Large Business & International. Practitioners representing MPP clients have addressed myriad issues including the scope and impact of joint investigations, the validity of summonses, treaty interpretations, applicable statutes of limitations, privileges and work product doctrine, and conflicts of interest. This panel will review those issues, discuss lessons learned and recent developments, and what may lay ahead as the government continues to pursue its parallel investigations.
Moderator:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Panelists:
Tom Cullinan, Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry
Kathy Enstrom, Director of Investigations, Moore Tax Law Group LLC
Daniel Price, Managing Member, Law Offices of Daniel N. Price, PLLC
Tuesday, March 5, 2024
2:00 PM – 3:00 PM: Caroline D. Ciraolo moderates a panel titled “We Live in Interesting Times – The Latest in Criminal Tax Investigations and Sentencings.”
Description: IRS Criminal Investigation and its partners within the Department of Justice have been hard at work pursuing individuals and entities believed to have engaged in willful tax violations. Recent criminal tax investigations involve syndicated conservation easements, Malta pension plans, international structures and accounts, cryptocurrency schemes, employment tax violations, pandemic-related fraud, and other high priority areas of enforcement. Many of these investigations involve complex and emerging issues, including the use of filter teams, acquisition and use of foreign based evidence, and constitutional challenges. At the other end of the lifecycle of a criminal tax case, defense counsel and prosecutors are addressing new developments in sentencings, including the consideration of intended tax loss and acquitted conduct, the Zero-Point Offender adjustment, the corresponding impact of role adjustments, and a renewed push to consider non-custodial sentences. Panelists will review these important issues, discuss recent developments, and offer best practices.
Moderator:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Panelists:
Sandra Brown, Principal, Hochman Salkin Toscher Perez P.C.
Eric Hylton, Director of Investigations, ZMF Law
Jeffrey Neiman, Partner, Marcus Neiman & Rashbaum LLP
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Multijurisdictional Ethics Issues – Working In Multiple Jurisdictions – Some Things You May Not Think About May Hurt You
2024-03-01 16:00 - 17:00 (America/New_York)
Megan Brackney will participate in a panel titled “Multijurisdictional Ethics Issues – Working in Multiple Jurisdictions – Some Things You May Not Think About May Hurt You” hosted by the 2024 Tax Law Conference on March 1, 2024 at the Ronald Reagan Building & International Trade Center.
Event Description:
Practitioners who represent foreign (and domestic) clients face problems that not only raise ethics issues (like practicing in more than one jurisdiction – e.g., license issues, language issues, as well as knowledge of other jurisdictions), but importantly may also involve them and their clients in a number of reporting requirements and even scrutiny under federal money laundering and other statutes that impose criminal liability. These situations require thought about due diligence on accepting clients from other jurisdictions who may have needs or motives besides having a house in your state – tax evasion, reporting of income and assets, etc. This panel will discuss matters you really need to consider and actions you need to take to represent clients with more complex investments and businesses.
This event is co-hosted by the Federal Bar Association’s Section on Taxation.
Moderator:
Fred Murray, Special Counsel, IRS, U.S. Department of the Treasury
Speaker:
Megan Brackney, Partner, Kostelanetz LLP
Matt Cooper, Managing Director, Tax Controversy Services, Deloitte Tax LLP
Emily Lesniak, Senior Level Counsel, Procedure and Administration, I.R.S., U.S. Department of the Treasury
Registration is now open. Please visit here for registration, and click here for event details.

American Bar Association's 39th Annual National Institute on White Collar Crime
2024-03-06 10:30 - 11:45 (America/Los_Angeles)
On March 6, 2024, Caroline D. Ciraolo speaks on a panel titled “Criminal Tax Enforcement – The Powers and Perils of Parallel Criminal and Civil Investigations” at the ABA’s 39th Annual National Institute on White Collar Crime.
Parallel investigations involving the IRS and federal tax matters by different state or federal government entities have become common practice. The panel will discuss the challenges and strategies when dealing with such proceedings, including issues that arise when government coordination may result in a determination of a “joint” rather than a parallel matter.
Wednesday, March 6, 2024
10:30am – 11:45am (PST)
Moderator:
Sandra R. Brown, Hochman Salkin Toscher Perez P.C.
Speakers:
Caroline D. Ciraolo, Kostelanetz LLP
Ronald L. Cheng, Pillsbury Winthrop Shaw Pittman LLP
Mary E. Hammond, Executive Director, Global Operations Policy & Support, IRS Criminal Investigation
Pamela M. Johnston, Foley & Lardner LLP

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