Bryan C. Skarlatos Participates In A Panel Entitled “Mastering Bitcoin, Blockchain and Digital Currency Law,” Hosted By Rossdale CLE
2021-05-26 12:00 - 13:30 (America/New_York)
On May 26, 2021, Bryan C. Skarlatos participates in a panel entitled “Mastering Bitcoin, Blockchain and Digital Currency Law,” hosted by Rossdale CLE.
Cryptocurrency, blockchain, and smart contracts have become one of the most profitable and fastest growing practice areas today. Shares of bitcoin have seen tenfold increases recently. There is a material need for attorneys to understand the latest legal issues involving these emerging payment markets and systems. These technologies can be as transformative as the internet and will create significant opportunities for legal expertise & growth. Fortune 500 companies, governments, and start-ups alike are all seeking to take advantage of this novel use of currency. The faculty for this seminar features three authorities on the subject. This comprehensive program will cover the most relevant issues and practical solutions, including Blockchain, alternative capital raising, distributed ledger, the growth of cryptocurrencies, role of digital currencies in financial transactions, “Smart Contracts,” compliance & avoidance strategies, and virtual currency transmissions. The faculty will also cover the changes and progress on future regulations. Registration includes online access to course and reference materials that serve as a helpful guide to the numerous topics and techniques discussed in the program.
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Megan L. Brackney Participates In A Presentation Entitled “Partnership Audits” For The 2020-2021 Portland Tax Forum
2021-05-27 10:30 - 12:00 (America/New_York)
On May 27, 2021, Megan L. Brackney participates in a presentation entitled “Partnership Audits” for the 2020-2021 Portland Tax Forum.
The Portland Tax Forum is a nonprofit corporation whose goal is to provide nationally recognized speakers on tax topics and to promote professional tax education to attorneys, certified public accountants and other tax professionals.
The 2020-2021 program features six online tax forums and stimulating lectures from nationally recognized speakers.
This program offers CLE credits. Registration is required.
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Caroline D. Ciraolo Participates In A Panel Entitled "Hot Topics on Dealing with International Taxpayers and Tax Treaties" At The California Lawyer’s Association Annual Estate And Gift Tax Conference
2021-05-28 09:15 - 11:15 (America/Los_Angeles)
On May, 28, 2021, Caroline D. Ciraolo participates in a panel entitled “Hot Topics on Dealing with International Taxpayers and Tax Treaties” at the California Lawyer’s Association Annual Estate and Gift Tax Conference.
Description: The panel will discuss tips and traps for international income and estate tax practitioners when using tax treaties to address an international taxpayer’s federal income, gift and estate tax planning issues. The panel will provide insights on treaty-shopping to maximize an international taxpayer’s US estate tax exemption and use of competent authority mechanism to resolve the “grey areas”, and issues that arise when dealing with Australia, Canada, and the PRC. The panel will also discuss model treaty provisions in US bilateral tax treaties and tax information exchange agreements that are used by tax authorities to request tax return information and tax collection assistance, including frequency of requests for information among tax authorities, the procedure in the U.S. for making requests and processing requests received, grounds and applicable procedures for challenging such requests under United States v. Powell, 379 U.S. 48 (1964), and its progeny, and recent related litigation.
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Caroline D. Ciraolo Participates In A Panel Entitled "Criminal Investigations and Civil Tax Audits" At The Center For Taxpayer Rights 5th International Conference On Taxpayer Rights
2021-05-28 17:15 - 18:30 (Europe/Athens)
On May, 28, 2021, Caroline D. Ciraolo participates in a panel entitled “Criminal Investigations and Civil Tax Audits” at the Center For Taxpayer Rights 5th International Conference on Taxpayer Rights: Quality Tax Audits and the Protection of Fundamental Rights.
Description: As tax agencies ramp up enforcement efforts, including cooperating internationally, the dividing line between civil tax audits and criminal investigations becomes blurred. This panel will explore the practices of various countries, considering whether the audit and criminal investigation run concurrently, whether there is a mens rea requirement for criminal tax sanctions, the application of the principle of proportionality, and the deterrent function of criminal sanctions. How are civil fraud penalties integrated with criminal sanctions. At what point is the taxpayer notified it is a target of criminal investigation? What is the overlap between tax audits and anti-money laundering initiatives and legislation?
Moderator: Nicolas Michon, Juge au Tribunal Judiciaire de Paris, France
Panelists: Caroline Ciraolo, Kostelanetz & Fink, LLP, United States – David Hummel, Legal Secretary, Court of Justice of the European Union, Luxembourg; Professor, University of Leipzig, Germany – Eleonor Kristoffersson, Professor, School of Law, Psychology and Social Work, Örebro University; Visiting Professor, Linköping University and Gävle University, Sweden
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Michael Sardar Participates In A Panel Entitled "What’s New in Criminal Tax" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 08:45 - 09:45 (America/New_York)
On June 4, 2021, Michael Sardar participates in a panel entitled “What’s New in Criminal Tax” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: IRS Leadership is sending a clear enforcement message. The panelists will address the current state of IRS Criminal Investigation, its enforcement priorities, recent prosecutions, and what practitioners are seeing in the field.
Moderator: Sara V. Spodick, Esq., Director, Low Income Taxpayer Clinic, Quinnipiac Law School
Panelists:
Michael Sardar, Esq., Kostelanetz & Fink, LLP, New York, NY
Joleen Simpson, Acting Special Agent-in-Charge, IRS Criminal Investigation, Boston Field Office
Frank Agostino, Esq., Agostino & Associates, PC, Hackensack, NJ
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Sharon McCarthy Moderates A Panel Entitled "Parallel Civil & Criminal Investigations" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 09:45 - 10:45 (America/New_York)
On June 4, 2021, Sharon McCarthy moderates a panel entitled “Parallel Civil & Criminal Investigations” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: Just over a year ago the IRS announced the creation of a new Fraud Enforcement Office and Damon Rowe, a seasoned veteran of IRS Criminal Investigation, as its new Director. Not long thereafter, the IRS appointed Carolyn Schenk as National Fraud Counsel. On this panel, they will discuss the increased focus on fraud enforcement, the engagement and collaboration with the IRS operating divisions, and the efforts to develop strong civil fraud cases and fraud referrals to IRS Criminal Investigations. The panel will also discuss risks to practitioners and taxpayers who may be subject to a criminal investigation they do not know exists.
Moderator: Sharon McCarthy, Esq., Kostelanetz & Fink, LLP, New York, NY
Panelists:
Barbara Kaplan, Esq., Greenberg Traurig, New York, NY
Damon Rowe, JD, CPA, Director, Fraud Enforcement Office, Internal Revenue Service, Washington, DC
Carolyn Schenk, Esq., National Fraud Counsel and Asst Division Counsel (International), SB/SE, Office of Chief Counsel, Internal Revenue Service, Washington, DC
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Jay Nanavati Participates In A Panel Entitled "PPP Loan Fraud" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 11:00 - 12:00 (America/New_York)
On June 4, 2021, Jay Nanavati participates in a panel entitled “PPP Loan Fraud” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: “My client used their PPP Loan money to pay for their kid’s medical school…is this going to be an issue?” The Paycheck Protection Program has been something of a whirlwind as hundreds of billions were quickly shoveled out. Thousands of accountants found themselves drafted into service as loan agents – mostly unpaid agents. And, shocking, there was fraud. Quite a bit of fraud. Join us for a discussion of the government’s efforts to crack down on fraudsters who took advantage of the PPP Loan program, what the IRS is doing about it and where enforcement is headed on this topic.
Moderator: Jeffrey Sklarz, Esq., Green & Sklarz LLC, New Haven, CT
Panelists:
Walter Pagano, CPA, CFE, Eisner Amper, Iselin, NJ
Jay Nanavati, Esq., Kostelanetz & Fink, LLP, Washington, DC
Zhanna A. Ziering, Esq., Caplin Drysdale, New York, NY
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Don Fort Participates In A Panel Entitled "The IRS’s Use of Artificial Intelligence in Criminal Tax Cases" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 12:30 - 13:30 (America/New_York)
On June 4, 2021, John D. (Don) Fort participates in a panel entitled “The IRS’s Use of Artificial Intelligence in Criminal Tax Cases” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: More and more the IRS is utilizing machine learning, referred to as Artificial Intelligence, or “AI”, in developing its cases. Payroll tax cases, collection cases with false disclosures and non-filer cases have been developed through the IRS’s use of AI. Our panel of experts will explain, to the extent they can discuss it, how the IRS uses AI and what information it can develop to aid the government in enforcement.
Moderator: Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Panelists:
Sarah Paul, Esq., Eversheds Sutherland, New York, NY
John D. (Don) Fort, Kostelanetz & Fink, LLP, Washington, DC (former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division)
Gary L. Alford, Supervisory Special Agent, IRS Criminal Investigation, New Haven, CT
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Bryan C. Skarlatos Moderates A Panel Entitled "Non-Filers" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 13:30 - 14:30 (America/New_York)
On June 4, 2021, Bryan C. Skarlatos moderates a panel entitled “Non-Filers” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: In May of 2020 a report was issued by the Treasury Inspector General for Tax Administration criticizing the IRS for knowing about more than 10 million non-filers, many of whom are high-income earners, and not pursuing them. The IRS assured us that, no, they do have a program and are pursuing them. So, a year later where is the IRS in regards to its non-filer program? Join our experts and hear what the IRS is doing to bring non-filers into the system and when does a taxpayer’s failure to comply constitute criminal behavior.
Moderator: Bryan C. Skarlatos, Esq. Kostelanetz & Fink, LLP, New York, NY
Panelists:
Sara Neill, Esq., Capes Sokol, St. Louis, MO
Hank Kea, Director, Field Collection Operations, Small Business/Self-Employed Division, Internal Revenue Service, Washington, D.C.
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Caroline D. Ciraolo Participates In A Panel Entitled "The Criminal Investigation Part 1: Inside The Defense Room" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 14:45 - 16:00 (America/New_York)
On June 4, 2021, Caroline D. Ciraolo participates in a panel entitled “The Criminal Investigation Part 1: Inside the Defense Room” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: Never been inside a conference room with defense counsel sorting out the taxpayer’s defense to potential criminal tax charges? This program will allow the attendees to walk into that conference room and listen in while the taxpayer and his defense counsel prepare for the conference with the government, and the forensic accountant reports what she has found. (Scripted Meeting.)
Taxpayer: Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Defense Counsel 1: Caroline D. Ciraolo, Esq., Kostelanetz & Fink LLP, Washington, DC
Defense Counsel 2: Frank Agostino, Esq., Agostino & Associates, PC, Hackensack, NJ
Forensic Accountant: Sareena Sawhney, MBA, CFE, Withum, Smith & Brown, PC, New York, NY
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Caroline D. Ciraolo Participates In A Panel Entitled "The Criminal Investigation Part 2: Meeting With The Government" At Quinnipiac University's 4th Annual Criminal Tax Day
2021-06-04 16:00 - 17:00 (America/New_York)
On June 4, 2021, Caroline D. Ciraolo participates in a panel entitled “The Criminal Investigation Part 2: Meeting with the Government” at Quinnipiac University’s 4th Annual Criminal Tax Day. The Fourth Annual Criminal Tax Day is a conference that provides educational CPE/CLE sessions for CPAs, EAs, and attorneys on the hottest criminal tax topics.
Description: After hearing the government’s case, the taxpayer decides to accept responsibility and plead guilty. A plea agreement is negotiated and signed, the taxpayer appears before the court, enters his plea, and is now preparing for sentencing. This last session welcomes you into the courtroom to observe the sentencing, followed by a debrief meeting with defense counsel and the defendant to discuss the sentence imposed and what lays ahead.
Moderator: Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT
Panelists:
Frank Agostino, Esq. Agostino & Associates, Hackensack, NJ
Caroline D. Ciraolo, Esq., Kostelanetz & Fink, LLP, Washington, DC
Anastasia King, Asst. United States Attorney, New Haven, CT
Jeffrey Miller, Supervisory Special Agent, IRS Criminal Investigation, White Plains, NY
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Caroline D. Ciraolo Participates In A Panel Entitled "The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home" At The Bahamas Financial Services Board
2021-06-08
On June 8, 2021, Caroline D. Ciraolo participates in a panel entitled “The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home” at the Bahamas Financial Services Board.
The Bahamas Financial Services Board (BFSB) represents an innovative commitment by the financial services industry and the Government of The Bahamas to promote a greater awareness of The Bahamas’ strengths as an international financial center.
Click here to visit BFSB’s website.

Jay Nanavati Participates In A Panel Entitled "The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home" At The Bahamas Financial Services Board
2021-06-08
On June 8, 2021, Jay Nanavati participates in a panel entitled “The U.S. Anti-Money Laundering Act of 2020: Strengthening AML Enforcement Abroad While Closing Loopholes at Home” at the Bahamas Financial Services Board.
The Bahamas Financial Services Board (BFSB) represents an innovative commitment by the financial services industry and the Government of The Bahamas to promote a greater awareness of The Bahamas’ strengths as an international financial center.
Click here to visit BFSB’s website.

Caroline D. Ciraolo Participates In A Presentation Entitled "Your Client Is Out of Compliance – What Now?" For The ASTPS Spring 2021 Conference
2021-06-10 12:30 - 13:30 (America/New_York)
On June 10, 2021, Caroline D. Ciraolo participates in a presentation entitled “Your Client is Out of Compliance – What Now?” for the American Society of Tax Problem Solvers’ Spring 2021 Conference.
The ASTPS Spring 2021 Conference offers advanced training opportunities and presentations for tax resolution professionals on hot topics that affect your IRS representation.
The conference offers CLE credits. Registration is required.
Click here for more information and to register.

Caroline Rule Participates In A Panel Entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” For The National Association Of Women Lawyers
2021-06-17 15:00 - 16:00 (America/New_York)
On June 17, 2021, Caroline Rule participates in a panel entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” for the National Association of Women Lawyers.
This program will address the scope and applicability of the common interest doctrine to communications among parties aligned in corporate transactions and litigation matters, and will discuss steps counsel can take to help protect such communications from later disclosure under the common interest doctrine.
Panelists:
Caroline Rule, Kostelanetz & Fink, LLP
Victoria Buter, Kutak Rock LLP
Jacqueline Rogers, Potter Anderson & Corroon LLP
Lisa Sarver, Kutak Rock LLP
Click here for more information and to register.

Megan L. Brackney Presents “Attorney-Client and Accountant-Client Privileges in the Tax Context” For CPA Academy
2021-06-23 16:00 - 17:00 (America/New_York)
On June 23, 2021, Megan L. Brackney presents “Attorney-Client and Accountant-Client Privileges in the Tax Context” for CPA Academy.
CPAs, Enrolled Agents, and other tax practitioners should understand the attorney-client and federally authorized tax practitioner privileges in the specific context of tax to ensure that they are protecting their clients’ communications. This panel will discuss the scope of attorney-client privilege, including the Kovel privilege, and the federally authorized tax practitioner privilege under Sec. 7525 of the Code. We will discuss the sometimes blurred lines between legal services and tax return preparation, questions of confidentiality and waiver of privilege for items disclosed on tax returns, and other privilege issues specific to tax.
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Caroline D. Ciraolo Co-Chairs A Panel Entitled "Criminal Tax Enforcement Across The Americas" At The Virtual 13th Annual U.S. And Latin American Tax Practice Trends Conference
2021-06-24 11:30 - 12:45 (America/New_York)
On June 24, 2021, Caroline D. Ciraolo co-chairs a panel entitled “Criminal Tax Enforcement Across the Americas” at the Virtual 13th Annual U.S. and Latin America Tax Practice Trends Conference for the American Bar Association Section of Taxation, the International Bar Association Taxes Committee, and the International Fiscal Association-USA Branch.
Governments around the world are actively investigating and prosecuting tax crimes. These investigations often focus on aggressive, complex tax planning strategies by companies and their officers, and sophisticated financial transactions of high wealth individuals and their professional advisors engaged in broad, cross-border conduct. To identify and effectively prosecute these cases, governments are deploying all available resources and investigative tools. This panel will address the state of criminal tax investigations and prosecutions across the Americas. The panelists will delve into the current enforcement priorities and discuss some of the “ripped from the headlines” cases in their respective jurisdictions.
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Don Fort Participates In A Panel Entitled "Global Corruption Challenges: The Need For Transparency, Training, And Effective Laws" For AML RightSource
2021-06-24 13:00 - 14:00 (America/New_York)
On June 24, 2021, Don Fort participates in a panel entitled “Global Corruption Challenges: The need for transparency, training, and effective laws” for AML RightSource.
This installment of the AML Voices series consists of a panel of experts discussing the challenges of global corruption from various perspectives, including regulatory, enforcement, advocacy, and global impact. Panelists include Tom Cardamone, Bob Pasley, Don Fort, and Pascale Dubois.
In this webinar, audience members learn about:

How international emergencies overwhelm compliance programs; how to close the gap on enforcement efforts against corrupt officials
Importance of existing and pending laws in impacting the efforts to reign in global corruption and fraud
The current administration’s focus on the adverse impact of global corruption; proposals in Congress on global corruption
Know Your Employee, FCPA, and Britain’s Anti-Corruption Act; Case Study from the Siemen’s Case

Click here for more information and to register.

Don Fort Presents At The Federal Law Enforcement Training Center ("FLETC") Leadership Academy
2021-06-24 13:00 - 15:00 (America/New_York)
Don Fort participates in a discussion titled “Leading Successfully Through Self-Awareness and Ownership” at the Federal Law Enforcement Training Center (“FLETC”) Leadership Academy. During his presentation, Fort discusses the importance of self-awareness, self-accountability and self-responsibility, and the pitfalls and challenges that managers at all levels can minimize and overcome through leader ownership.
The Leadership Academy takes place from 1:00 – 3:00 pm EDT on Thursday, June 24, 2021, and is a free event open to sworn law enforcement officials and agents.

Megan L. Brackney Participates In A Panel Entitled "Tips For Handling Audits Of Pass-Through Entities Under The Centralized Partnership Audit Regime" At The NYU Tax Controversy Forum
2021-06-24 17:00 - 18:00 (America/New_York)
On June 24, 2021, Megan L. Brackney participates in a panel entitled “Tips for Handling Audits of Pass-Through Entities Under the Centralized Partnership Audit Regime” at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business.
The use of partnerships and other flow-through structures has continued to expand and now accounts for over 50% of all net business income in the United States. With a growing consensus around increased funding for the IRS, a significant uptick in partnership examination activity is expected, focusing particularly on complex ownership arrangements, cross-boarder activities and structured transactions. For most, these examinations will be conducted under the new centralized partnership audit regime. For partnerships who elect out of the centralized audit regime, the IRS will have to audit, assess and collect from individual partners. This panel discusses practical topics such as how the IRS links partnership and partner cases in its systems, IRS’ challenges in obtaining statute extensions from all partners, the potential for inconsistent results, and strategies for representing partnerships that have opted out of the centralized audit regime.
Moderator:
Mike Desmond, Gibson Dunn & Crutcher, LLP, Los Angeles, CA
Panelists:
Megan Brackney, Kostelanetz & Fink, LLP, New York, NY
Rochelle Hodes, Crowe, LLP, Washington, DC
Holly Paz, Deputy Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC
Click here for more information and to register.

Equal Footing With Dov Tuzman Interviews Christopher M. Ferguson On The Emotional And Psychological Toll On Lawyers Facing Undesirable Outcomes For Their Clients
2021-06-25
In the third segment of a three-part series entitled, “Rescuing the Rescuer,” K&F partner, Christopher M. Ferguson, joins Dov Tuzman on the radio show, Equal Footing with Dov Tuzman, to discuss the emotional and psychological toll on lawyers when they are unable to “save” their client or achieve justice for a victim.
Listen to the full interview here.

Bryan C. Skarlatos Moderates A Panel Entitled "New Leadership In The Taxpayer Advocate's Office: One Year Later" At The NYU Tax Controversy Forum
2021-06-25 13:00 - 13:30 (America/New_York)
On June 25, 2021, Bryan C. Skarlatos moderates a panel entitled “New Leadership in the Taxpayer Advocate’s Office: One Year Later” at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business.
On March 30, 2020, just as the Pandemic hit, Erin Collins took over as the new National Taxpayer Advocate to lead the Taxpayer Advocate Service. Before becoming the Taxpayer Advocate, Ms. Collins represented taxpayers before the IRS in private practice and she brings that perspective to TAS. This panel covers the types of matters TAS handles, tips on how to open cases, challenges presented by the Pandemic and will provide insight into the role that TAS plays in IRS compliance and enforcement.
Moderator:
Bryan Skarlatos, Kostelanetz & Fink, LLP, New York, NY
Panelist:
Erin M. Collins, National Taxpayer Advocate, Internal Revenue Service, Washington, DC
Click here for more information and to register.

Don Fort Moderates A Panel Entitled "What's New In IRS Criminal Investigations" At The NYU Tax Controversy Forum
2021-06-25 13:30 - 14:00 (America/New_York)
On June 25, 2021, Don Fort moderates a panel entitled “What’s New in IRS Criminal Investigations” at the NYU Tax Controversy Forum, hosted by NYU School of Professional Studies and the Division of Programs in Business.
Schemes to defraud the IRS are becoming more complex every day and IRS Criminal Investigation is responsible for investigating and prosecuting those intent on paying less than their share of tax. CI special agents are trained to use specialized technology to wade through computerized financial records and recover data to help prosecute tax evasion. The globalization of business transactions, the pandemic, and a limited budget have made CI’s job even more challenging. This panel features the former and current Chiefs of IRS CI, discussing how the IRS will meet these challenges and continue to enforce the tax law.
Moderator:
Don Fort, Kostelanetz & Fink, LLP, Washington, DC
Panelist:
Jim Lee, Chief, Criminal Investigation, Internal Revenue Service, Washington DC
Click here for more information and to register.

Caroline D. Ciraolo Presents "The IRS is Focused on Enforcement – What You Need to Know” For The 2021 CBIZ Virtual Tax Conference
2021-07-21
On July 21, 2021, Caroline D. Ciraolo presents “The IRS is Focused on Enforcement – What You Need to Know” for the 2021 CBIZ Virtual Tax Conference.
Description: In March 2020, the IRS formed the Office of Fraud Enforcement and appointed a former IRS Special Agent in Charge and Director of International Operations to lead its development. Since then, the IRS has appointed a National Fraud Counsel, enhanced fraud training efforts across the IRS operating divisions, reinforced fraud referral procedures with subject matter experts, published new compliance campaigns, and initiated civil examinations and criminal investigations of taxpayers participating in, and promoters of, abusive tax avoidance schemes. In April 2021, the IRS established the Office of Promoter Investigations to focus on priority areas including, but not limited to, micro-captive insurance, syndicated conservation easements, and Puerto Rico residency programs. While these transactions can be the subject of abuse, they are not inherently improper and practitioners need to be prepared to defend reasonable positions. This session will discuss the current state of enforcement, recent developments and litigation, defenses being raised, and what we can expect in the days to come.

Megan L. Brackney Participates In A Panel Entitled "Cryptocurrency: Navigating Minefields in the Virtual Currency World" For The IFA USA
2021-07-28 13:30 - 14:30 (America/New_York)
On July 28, 2021, Megan L. Brackney participates in a panel entitled “Cryptocurrency: Navigating Minefields in the Virtual Currency World” for the USA Branch of the International Fiscal Association. The IFA USA is hosting its New York Regional Conference virtually on Wednesday, July 28 and Thursday, July 29. The purpose of this panel is to help audience members understand ethical considerations related to cryptocurrency, analyze ethical issues of case studies in the cryptocurrency space, and identify ethical rules that apply to cryptocurrency transactions.
Moderator:
Pam Fuller, International Tax Counsel at Tully Rinckey and Zahn Law Group
Panelists:
Megan L. Brackney, Esq., Kostelanetz & Fink, LLP
Rebecca Lee, Principal, PwC
Lawrence Zlatkin, Vice President Tax, Coinbase
Click here for more information and to register.

Henry Stow Lovejoy Participates In A Webinar Entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” For Strafford Publications
2021-08-03 13:00 - 14:50 (America/New_York)
On August 3, 2021, Henry Stow Lovejoy participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford Publications.
Course Description:
Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, is one of the most complicated forms of all U.S. filing requirements concerning foreign persons. Initially, the reporting obligations applied to corporations only; now the requirements extend to DREs active in the U.S. owned by non-U.S. individuals and corporations.
IRC 6038A, IRC 6038C, and the regulations thereunder require a “reporting corporation” to disclose specified “reportable transactions” it has with any “related parties” on Form 5472. Defining these elements is highly sophisticated, so tax advisers must have a thorough grasp of each aspect to ensure that the taxpayer has disclosed all reportable transactions and met the record maintenance requirements to support its tax position for these transactions.
In response to scenarios in which foreign individuals and corporations were conducting business in the U.S. through DREs to avoid information reporting, the Service now requires foreign-owned single-member LLCs and other DREs to file Form 5472.
Foreign persons owning a U.S. domestic DRE, either directly or indirectly through attribution rules, must obtain necessary taxpayer-identification numbers and disclose reportable transactions. Penalties for failing to file Form 5472 are $25,000 per failure, with complicated rules for penalty mitigation.
Listen as our experienced panel provides a thorough and practical guide to completing Form 5472, including key definitions and a discussion of the expanded filing requirements.
Speakers:
Henry Stow Lovejoy, Kostelanetz & Fink, LLP
John Samtoy, Holthouse Carlin & Van Trigt LLP
Click here for more information and to register.

Don Fort Participates In A Webcast Entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” For The New York City Bar Association
2021-08-05 18:00 - 19:30 (America/New_York)
On August 5, 2021, Don Fort participates in a webcast entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” for the New York City Bar Association.
Description: The CLE will include an in depth discussion of hot topics in the taxation of virtual currency. The panelists, both current and former IRS Office of Chief Counsel attorneys and professionals, will provide tips and guidance on compliance and reporting issues and navigating IRS audits and information requests. The panel will also discuss IRS initiatives to investigate tax crimes involving virtual currency, and recent IRS developments and official guidance.
Click here for more information and to register.

Stephen A. Josey Co-Chairs And Moderates A Webcast Entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” For The New York City Bar Association
2021-08-05 18:00 - 19:30 (America/New_York)
On August 5, 2021, Stephen A. Josey co-chairs and moderates a webcast entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” for the New York City Bar Association.
Description: The CLE will include an in depth discussion of hot topics in the taxation of virtual currency. The panelists, both current and former IRS Office of Chief Counsel attorneys and professionals, will provide tips and guidance on compliance and reporting issues and navigating IRS audits and information requests. The panel will also discuss IRS initiatives to investigate tax crimes involving virtual currency, and recent IRS developments and official guidance.
Click here for more information and to register.

Caroline D. Ciraolo Participates In A Panel Entitled “Voluntary Disclosure Practice 2021 and Beyond” For The Texas Bar’s 39th Annual Tax Law: Practicing Tax Law In Uncertain Times Program
2021-08-20 15:00 - 16:00 (America/New_York)
On August 20, 2021, Caroline D. Ciraolo participates in a panel entitled “Voluntary Disclosure Practice 2021 and Beyond” for the Texas Bar’s 39th annual Tax Law: Practicing Tax Law in Uncertain Times program.
Description: In light of the current and anticipated increase in civil and criminal tax enforcement, Caroline Ciraolo and Daniel Price review the IRS Relief Procedures for Former U.S. Citizens and the current Voluntary Disclosure Practice, including extensive updates to the Internal Revenue Manual provisions that address eligibility, the lookback period and penalty framework, cooperation requirements, and revocation procedures.
Click here for more information and to register.

Don Fort Delivers Keynote Speech For The 38th International Symposium On Economic Crime
2021-09-06 03:00 - 06:00 (America/New_York)
On September 6, Don Fort delivers a keynote address for the 38th International Symposium on Economic Crime.
Description: The 38th International Symposium on Economic Crime at Jesus College, Cambridge brings together from across the globe a unique level and depth of expertise to address one of the biggest threats facing the stability and development of all our economies. The overarching theme for this year’s symposium focuses on who is actually harmed and pays for economically motivated crime and who should be held more accountable.
Click here for more information.
