Don Fort Participates In A Panel And Plenary Workshop Entitled "Professionals and the potential for abuse of trust – a US perspective" At The 39th Cambridge International Symposium On Economic Crime
2022-09-06 13:30 - 16:00 (America/New_York)
On September 6, 2022, Don Fort participates in a panel and plenary workshop entitled “Professionals and the potential for abuse of trust – a US perspective” at the 39th Cambridge International Symposium on Economic Crime at Jesus College, University of Cambridge, England.
Chair: Mr. Ian M. Comisky, Partner, Fox Rothschild LLP, Philadelphia and former Assistant US Attorney, Southern District of Florida, USA

Panelists:

Professor Barry Rider, Founder and Executive Director and Co-Chairman of the Symposium and Professorial Fellow, Centre of Development Studies, University of Cambridge, UK
Mr. Don Fort, Director of Investigations, Kostelanetz and Fink, LLP and former Chief, Criminal Investigations, Internal Revenue Service, US Department of Treasury, Washington DC, USA
Mr. Larry A. Campagna, Partner, Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, USA

Click here for more information.

Caroline D. Ciraolo Moderates A Panel Entitled "Getting your house in order – conducting internal investigation into alleged tax offenses” At The 39th Cambridge International Symposium On Economic Crime
2022-09-06 16:15 - 17:15 (Europe/London)
On September 6, 2022, Caroline D. Ciraolo moderates a panel entitled “Getting your house in order – conducting internal investigation into alleged tax offenses” at the 39th Cambridge International Symposium On Economic Crime at Jesus College, University of Cambridge, England.
Panel Description: With the increasing threat of Government enforcement, data leaks, and whistleblower complaints, companies need an established and effective protocol for investigating alleged violations of local or international laws. Particularly when dealing with potential tax violations, the failure to conduct a thorough and careful internal investigation can result in substantial monetary and other penalties and personal exposure for individuals involved. Panelists from England, France, and the United States will share their experience leading and managing internal investigations involving potential tax violations, review some of the difficult issues presented in dealing with officers, employees, and external witnesses, and best practices.
Moderator
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, LLP
Panelists
Polly Sprenger, Partner, Katten Muchin Rosenman LLP
Sandra R. Brown, Principal, Hochman Salkin Toscher Perez P.C.
Alice Rousseau, Partner, Rousseau and Sussman Advocates
Click here for more information and to register.

Bryan C. Skarlatos Participates In A Panel Discussion Entitled “Attorney-Client and Work Product Protections: What Will Remain After The Latest Government and Non-Government Initiatives"
2022-09-29 16:00 - 17:00 (America/Los_Angeles)
On September 29, 2022, Bryan C. Skarlatos participates in a panel discussion entitled “Attorney-Client Privilege and Work Product Protections: What Will Remain After The Latest Government and Non-Government Initiatives.”
Description: The Gatekeeper Initiative proposes to require some attorneys to evaluate and possibly “turn in” their clients. This program will discuss the history of the attorney-client and work product protections, current case law limiting the privilege as well as current American Bar Association and proposed legislative initiatives which would result in extraordinary changes in the attorney-client relationship. This program will cover the following topics:

Discuss the attorney-client privilege and work product protections
Review historical case law with respect to the privilege and protection
Discuss recent case law limiting the privilege
Explore proposed legislation with respect to attorney disclosures
Predict the effect of proposed changes on the attorney-client relationship

Panelists

Ian Comisky, icomisky@foxrothschild.com
Bryan C. Skarlatos, bskarlatos@kflaw.com

Stephen A. Josey Participates In A Panel Entitled “Diversity in the Tax Bar” For The Law Firm Anti-Racism Alliance's Tax System Working Group Discussion Series
2022-09-30 14:00 - 15:30 (America/New_York)
On September 30, 2022, Stephen A. Josey participates in a panel entitled “Tax System Working Group Discussion Series: Diversity in the Tax Bar” for the Law Firm Anti-Racism Alliance.
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, has organized a ten-part discussion series on diversity in the tax bar. Please join us for the final installment of this series to hear the four LFAA Tax System Working Group reporters discuss what they learned over the course of the first nine sessions, followed by a keynote speech from U.S. Tax Court Judge Maurice B. Foley. Whether you are an established member of the tax bar, a young lawyer, or a law student, this is a must-attend event for everyone who cares about creating sustainable diversity, equity and inclusion strategies for the tax profession.
Moderator:

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

Panelists:

Sanessa Griffiths, Skadden, Arps, Slate, Meagher & Flom, LLP
Stephen Josey, Kostelanetz & Fink, LLP
Alyssa Pratt, Foley Hoag, LLP
Lena Qiu, Perkins Coie, LLP

Keynote Speaker:

Judge Maurice B. Foley, U.S. Tax Court

Click here for more information and to register.

Caroline D. Ciraolo Presents On "The Role of DOJ in Tax Enforcement" At Georgetown University Law Center
2022-10-05 12:00 - 13:00 (Pacific/Honolulu)
Caroline D. Ciraolo presents on “The Role of DOJ in Tax Enforcement” to the Georgetown Tax Scholars at Georgetown University Law Center on October 5, 2022.

Caroline D. Ciraolo Delivers The 2022 Fogel Lecture Titled "Enforcing the Nation's Tax Laws Fully, Fairly, and Consistently - The Role of DOJ in Tax Enforcement" At Temple University, Beasley School of Law
2022-10-11 12:00 - 13:00 (Pacific/Honolulu)
Caroline D. Ciraolo delivers the 2022 Frank & Rose Fogel Lecture titled “Enforcing the Nation’s Tax Laws Fully, Fairly, and Consistently – The Role of DOJ in Tax Enforcement” at Temple University, Beasley School of Law in Philadelphia, PA.
The Department of Justice Tax Division is responsible for enforcing our country’s tax laws through civil and criminal litigation. The Tax Division strives to promote voluntary compliance, maintain public confidence in the integrity of the tax system, and promote the sound development of the law. The 2022 Fogel Lecture will discuss the role of the Tax Division in civil and criminal tax enforcement, how the Tax Division interacts with the IRS and other stakeholders, and the exciting employment opportunities within the Division.
The Fogel Lecture is hosted by Temple Law’s Center for Tax Law and Public Policy.
Click here to register.

Claude Millman Speaks At A Panel Entitled "What to Know about Doing Business in New York" In The 2022 Government Procurement Conference
2022-10-13 10:30 - 11:30 (America/New_York)
Claude M. Millman joins a panel entitled “What to Know about Doing Business in New York” at the Government Procurement Conference on October 13, 2022 at The Museum of Jewish Heritage in New York.
Panel Description: This panel will provide an inside look at the New York City and State procurement processes and prepare audience members to navigate the evolving systems. Among other things, the panel will discuss strategies to address potential challenges arising from an economic downturn, tips to win bidding processes, the complexity of requests for proposals (RFPs), and what NY government entities want from potential contractors.
Moderator:

Katie Schwab, Managing Director, Cozen O’Connor Public Strategies

Panelists:

Claude M. Millman, Partner, Kostelanetz & Fink, LLP
Brad Lander, Comptroller, New York City
Paul Murray, Director, Bureau of Procurement Enterprise Services, New York State Office of Mental Health
Julie Won, Chair, New York City Council Committee on Contracts
Adam Buchanan, Principal, Capalino
Christopher Burke, Executive Director, New York State Preferred Source Program for New Yorkers Who are Blind (NYSPSP)

Click Register here to register.

Jay Nanavati Participates In A Panel For The DC Bar On The Corporate Transparency Act
2022-10-19 11:30 - 12:45 (America/New_York)
On October 19, 2022, Jay R. Nanavati addressed the DC Bar in a panel entitled “Corporate Transparency Act: Are You Ready?”.
Panel Description: When FinCEN recently issued its final regulations regarding who must report information under the Corporate Transparency Act, many practitioners shrugged and filed the story for future reading. While the regulations will not go into effect until January 1, 2024, there will be significant ground for reporting companies and their advisors to cover to prepare for the new reporting regime. What exactly is this new beneficial ownership database? Who must report, what information, and when? Come hear from a panel of seasoned civil and criminal tax controversy attorneys who have been closely tracking the developments in this area.
Speakers:

Jay Nanavati, Partner, Kostelanetz & Fink LLP
Joseph Rillotta, Member, Miller & Chevalier
Melissa Wiley, Member, Caplin & Drysdale, Chartered

Click here for more information.

Don Fort Joins A Panel Titled "Criminal Tax Trends" At The 2022 Freeman Law International Tax Symposium
2022-10-20 09:40 - 22:30 (America/New_York)
Don Fort joins a panel titled Criminal Tax Trends at the 2022 Freeman Law International Tax Symposium. The symposium assembles tax experts from across the world to discuss tax trends that are reshaping international taxation. It sets the stage for attorneys to learn about topics such as global tax reform, international civil penalty enforcement, transfer pricing development, cryptocurrency global enforcement trends, and cross-border tax planning opportunities.
Panelists:

Don Fort, Director of Investigations, Kostelanetz & Fink, LLP
Carolyn Schenck, IRS National Fraud Counsel and Assistant Division Counsel (International)
Nanette Davis, Senior Litigation Counsel, Department of Justice Tax Division

Click here to register.

Caroline D. Ciraolo Joins A Panel Titled "International Tax & Trade Investigations And Voluntary Disclosures" At The 2022 Freeman Law International Tax Symposium
2022-10-20 10:40 - 23:30 (America/New_York)
Caroline Ciraolo joins a panel titled “International Tax & Trade Investigations and Voluntary Disclosures” at the 2022 Freeman Law International Tax Symposium. The symposium assembles tax experts from across the world to discuss tax trends that are reshaping international taxation. It sets the stage for attorneys to learn about topics such as global tax reform, international civil penalty enforcement, transfer pricing development, cryptocurrency global enforcement trends, and cross-border tax planning opportunities.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Josh Wu, Counsel, Latham & Watkins LLP
Olga Torres, Managing Member, Torres Trade Law
Matthew Robert, Principal, Freeman Law

Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "From The Experts: Tax Controversy And Tax Litigation - Civil & Criminal Tax Update" At The 81st Institute On Federal Taxation
2022-10-23 13:15 - 15:45 (America/New_York)
Caroline D. Ciraolo participates in a panel titled “From The Experts: Tax Controversy And Tax Litigation – Civil & Criminal Tax Update” on October 23, 2022 at the 81st Institute on Federal Taxation in New York.
Panel Description: Join a leading group of tax controversy practitioners from both the private sector and the government in an open discussion regarding current IRS enforcement priorities, initiatives, and campaigns, including areas impacted by the Inflation Reduction Act of 2022 (IRA). The panel covers a broad range of topics that impact tax compliance and tax litigation, including an examination of recent cases, investigations, and programs – such as the IRS’s new Emerging Issues Group – that reflect the government efforts to target high risk areas of noncompliance, including the increased role that the IRS Collection Division plays in tax administration, as well as approaches to representing and defending clients who are the focus of such investigations.
Panelists:

Frank Agostino, Esq., Founder & President, Agostino & Associates, PC, Hackensack, NJ
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
Kristina L. Rico, Esq., Senior Counsel, Office of Chief Counsel, Small Business/Self-Employed Division, National Fraud Counsel Team, Internal Revenue Service, Philadelphia, PA

Click here to register.

Garrett L. Brodeur Participates In A Panel Entitled "Exploring Tax Practice Settings With Alumni" For Students Of The Georgetown Law Center Tax LL.M. Program
2022-10-25 12:00 - 13:00 (America/New_York)
Garrett L. Brodeur participates in a panel titled “Exploring Tax Practice Settings With Alumni” for students of the Georgetown Law Center Tax LL.M. Program on October 25, 2022.
Panelists:

Garrett L. Brodeur, Kostelanetz LLP
Ballinger Doyle, Grant Thornton
Camilah Gould-Bailey, Google Tax
Saiya Savooji, KPMG Canada

This panel was only available to students of the Georgetown Law Center Tax LL.M. Program. Click here to view a recording of the panel.

Kostelanetz And The Morehouse-Spelman Pre-Law Society Host A Program Entitled “From Spelman to Law School: A Conversation with Kennedy Mackey, Destiny Reese, & Grace Hall”
2022-10-25 19:00 - 20:00 (America/New_York)
On October 25, 2022, Mia Bailey and Mariana Gusdorf, members of the Pre-Law Paralegal Program at Kostelanetz LLP, moderated a panel entitled “From Spelman to Law School: A Conversation with Kennedy Mackey, Destiny Reese, & Grace Hall” for the Morehouse-Spelman Pre-Law Society (MSPLS). Kennedy, Destiny, and Grace are former alumnae of Spelman College and Kostelanetz’s Spelman College Pre-Law Internship Program. They left the firm in 2022 to attend Harvard Law School, Emory University School of Law, and the University of Virginia School of Law, respectively. (Previously, all three alumnae had discussed their experiences at Kostelanetz and their hopes for the future of the program.)
Kostelanetz launched its Spelman internship in 2021 and became a sponsor of the MSPLS later that year.
The MSPLS panel served as an opportunity for MSPLS members to learn about the various paths to law school from the perspectives of the program’s first three alumnae. Over 50 people attended the program.
During the event, MSPLS members asked the panelists questions such as:
• What made you want to pursue a career in law?
• What made you want to work at a law firm in between college and law school?
• Can you share some pros and cons of choosing to take a gap year between undergrad and law school versus going straight from undergrad to law school?
• Do you have any advice on taking a gap year versus going straight from undergrad to law school?
At the end of the program, Mia and Mariana described the Spelman Internship program at Kostelanetz and the process for applying to it.

Megan L. Brackney Participates In A Panel Entitled "When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice" At The 81st Institute On Federal Taxation
2022-10-27 17:15 - 18:55 (America/New_York)
Megan L. Brackney participates in a panel titled “When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice” on October 27, 2022 at the 81st Institute on Federal Taxation in New York.
Panel Description: How sure do you have to be before you tell a client it is okay to take a deduction or defer income? Do you have to audit a client’s records or can you just rely on what the client says? After the return has been filed, how do you handle an audit when you know the client’s tax return is wrong? What do you do if the information you submitted to the IRS is not accurate? When do you have to worry about conflicts of interest? While the answers to these questions may not always be clear, the law and related ethical standards provide very specific rules to help find the answers. This panel of expert practitioners addresses these and other thorny ethical issues that arise in everyday tax practice through the use of hypothetical examples. This program is essential for tax professionals who want to stay on the right side of the line.
Panelists:

Megan L. Brackney, Esq., Partner, Kostelanetz, New York, NY
Christopher S. Rizek, Esq., Member, Caplin & Dysdale, Chartered, Washington, DC

Click here to register.

Caroline D. Ciraolo Participates In A Panel Titled "Current Tax Disputes Trends at a Domestic and Cross Border Level" At The October IFA UK Branch Meeting
2022-10-27 18:00 - 19:30 (Europe/London)
Caroline D. Ciraolo joins a panel titled “Current Tax Disputes Trends at a Domestic and Cross Border Level” at the International Fiscal Associations UK branch meeting held on October 27, 2022.
Panel Description:
Panelists from around the world offer their unique perspectives on civil and criminal tax enforcement and trends in the United Kingdom, United States, Israel, India, and Finland.
Panelists:

Liesl Fichardt, Head of International Tax and Regulatory Investigations and Disputes, Quinn Emanuel, UK
Parul Jain, Co-Head, International Tax Practice, Nishith Desai Associates, India
Ofer Granot, Partner, Herzog, Fox & Neeman, Israel
Caroline Ciraolo, Partner, Kostelanetz LLP, Washington, DC
Jouni Weckström, Partner, Waselius & Wist, Finland

Click here for more information.

Three K&F Attorneys Participate In Ethics Panels At The "Tax Strategies 2022" Conference
2022-10-28
Bryan Skarlatos, Caroline Ciraolo, and Megan Brackney serve as panelists at the Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2022 (“Tax Strategies 2022”) conference. The panel is titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know.”
Mr. Skarlatos serves as a panelist at the New York City Tax Strategies 2022 conference on October 28, 2022. Ms. Brackney speaks at the Chicago conference on November 18, 2022, and Ms. Ciraolo presents at the Los Angeles conference on December 9, 2022.
Panel Description:
Ethical rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit; the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct
Click here to register.

Megan L. Brackney Speaks About "Stages of a Tax Controversy" At The 2022 Heart Of America Tax Institute Conference
2022-11-04 10:20 - 11:20 (America/New_York)
Megan L. Brackney speaks about “Stages of a Tax Controversy” at the Heart of America Tax Institute Conference on November 4, 2022. This annual conference offers attorneys the opportunity to learn about a wide array of topics such as updates on state and local tax, partnership tax, estate planning, corporate tax, and ethical obligations for tax professionals.
Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Tax Treaties For The Estate Planner" At The California Lawyers Association Taxation Section's 2022 Annual Meeting Of The Tax Bar And Tax Policy Conference
2022-11-04 15:30 - 17:00 (America/Los_Angeles)
Caroline D. Ciraolo participates in a panel entitled “Tax Treaties for the Estate Planner” at the California Lawyers Association, Taxation Section’s 2022 Annual Meeting of the Tax Bar and Tax Policy Conference. The panel will discuss important issues under income, and estate and gift tax treaties. It will also cover the exchange of information under such treaties and/or FATCA agreements and other associated issues.
Panelists:

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

Click here to register. Please note that MCLE credit is being offered for this event.

Caroline D. Ciraolo Participates In A Panel Titled "Using the IRS's Taxpayer Advocate Service to Help Taxpayers Across the Country" At The 59th Annual Hawaii Tax Institute
2022-11-07 16:00 - 17:00 (Pacific/Honolulu)
Caroline D. Ciraolo joins a panel titled “Using the IRS’s Taxpayer Advocate Service to Help Taxpayers Across the Country” at the 59th Annual Hawaii Tax Institute. This panel will discuss how the IRS’s National Taxpayer Advocate can help taxpayers address federal tax issues and mitigate taxpayer problems. Explore the internal workings of the IRS’ Taxpayer Advocate Service, the kind of facts and cases they address/resolve, and how all federal taxpayers and their Wealth Transfer Advisors can use this “voice of the taxpayer”.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Kurt Kawafuchi, Principle, Law Offices of Kurt Kawafuch
Erin M. Collins, National Taxpayer Advocate, Internal Revenue Service

Click here to register. Please note the event will be taking place in PST time.

Caroline D. Ciraolo Participates In A Panel Titled "Foreign Trusts and Gifts - Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!" At The 59th Annual Hawaii Tax Institute
2022-11-08 13:30 - 14:30 (Pacific/Honolulu)
Caroline D. Ciraolo joins a panel titled “Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!” at the 59th Annual Hawaii Tax Institute.
We live in a global economy and many clients have sources of income and assets outside the United States. For U.S. persons, this means having to comply with a complex web of reporting obligations under the Internal Revenue Code and the Bank Secrecy Act. This panel will address reporting requirements for foreign trusts (including Australian Superannuation funds, Liechtenstein Anstalt, Mexican fideicomiso, Canada tax saving and retirement plans, Stiftungs, and Usufructs), and the receipt of gifts from foreign individuals and entities. Learn about the consequences of noncompliance, paths to compliance, and best practices in challenging the often substantial penalties.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Marsha Dungog, Partner, Withers Worldwide
Kurt Kawafuchi, Principle, Law Offices of Kurt Kawafuchi

Click here to register. Please take note that this event will take place in PST time.

Caroline D. Ciraolo and Don Fort Participate In A Panel Titled "When Aggressive Tax Planning Becomes Criminal Conduct" At The 59th Annual Hawaii Tax Institute
2022-11-10 12:30 - 13:30 (Pacific/Honolulu)
Caroline D. Ciraolo and Don Fort join a panel titled “When Aggressive Tax Planning Becomes Criminal Conduct” at the 59th Annual Hawaii Tax Institute.
High income taxpayers frequently look to minimize their tax burdens and tax professionals are only too happy to oblige with one planning structure or another. It is when these structures cross the line that the Government sounds the alarm. When tax-advantaged transactions are “too good to be true,” “lack economic substance,” “lack business purpose,” or are deemed to be economic scams, taxpayers and their advisors can face civil audits and promoter investigations, both resulting in substantial civil penalties, professional licensing issues, and injunctions. When the Government believes that the individuals involved intentionally violated the rules – lying, cheating, or stealing – the matter can quickly move into the criminal realm. This panel will review what causes the Government to initiate a criminal tax investigations, ethical considerations for wealth transfer advisors, the roles of IRS-CI, the Justice Department’s Tax Division, and the U.S. Attorney’s Office, the transactions and structures currently targeted by the IRS, and “ripped from the headlines” criminal tax prosecutions.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Don Fort, Director of Investigations, Kostelanetz LLP
Evan Davis, Principal, Hochman Salkin Toscher Perez PC
Rebecca Perlmutter, AUSA, U.S. Attorney’s Office, District of Hawaii

Click here to register. Please note the event will be taking place in PST time.

Bryan C. Skarlatos Participates In A Panel Discussion Entitled "Criminal Tax Enforcement" At The UCLA Extension 38th Annual Tax Controversy Institute
2022-11-14 11:00 - 19:50 (America/New_York)
Bryan C. Skarlatos participates in a panel discussion entitled “Criminal Tax Enforcement” on October 27th at the UCLA Extension 38th Annual Tax Controversy Institute. The virtual re-broadcast is available on November 14, 2022.
Panel Description:
This panel covers criminal tax proceedings arising under the Internal Revenue Service’s laws, including the roles of the criminal tax attorney, tax fraud investigations, and IRS criminal investigations.
Moderator:

Sandra R. Brown, Hochman Salkin Rettig Toscher & Perez, P.C.

Panelists:

Bryan C. Skarlatos, Esq., Kostelanetz LLP
Tyler R. Hatcher, IRS-CI Special Agent in Charge, Los Angeles Field Office
Damon Rowe, Meadows Collier Reed Cousins Crouch & Underman, LLP
Lorraine Yu, IRS Chief Counsel, Criminal Tax Counsel

Click here to register for the virtual re-broadcast.

Garrett L. Brodeur Speaks About Current Supreme Court Case, Bittner v. United States, At The ABA Tax Section Administrative Practice Committee November Meeting
2022-11-17 12:00 - 13:00 (America/New_York)
Garrett L. Brodeur speaks about the current Supreme Court case, Bittner v. United States (No. 21-1195), at the ABA Tax Section Administrative Practice Committee’s Monthly Lunch Meeting on November 17, 2022. The presentation will focus on the oral arguments heard before the Court on the morning of November 2nd, 2022.
Meeting Description: The meeting will cover updates on the following important and closely-watched cases:

U.S. v. Bittner, No. 21-1195: Is a “violation” under the Bank Secrecy Act the failure to file an annual FBAR or is there a separate violation for each individual account that was not properly reported. The Supreme Court heard oral arguments on November 2, 2022.
Green Valley Investors, LLC, 159 T.C. No. 5 (November 9, 2022): The US Tax Court held that the IRS could not impose penalties for failure to comply with Notice 2017-10, designating conservation easements as listed transactions, because the Notice skipped notice-and-comment rulemaking required under the Administrative Procedure Act.
In re Grand Jury Proceeding, No. 21-1397. On October 3, 2022, the Supreme Court granted certiorari to consider if a communication involves both legal and non-legal advice, when is it protected from disclosure by the attorney-client privilege?

Speakers:

Garrett L. Brodeur, Kostelanetz LLP, Co-Counsel for Amicus Curiae American College of Tax Counsel.
Susan Combs, Holland & Hart LLP.

Caroline D. Ciraolo Presents "Ethics: When Aggressive Tax Planning and Controversy Defense Become Criminal Conduct" At The 71st Tulane Tax Institute
2022-11-17 16:45 - 17:45 (America/New_York)
Caroline D. Ciraolo speaks on “Ethics: When Aggressive Tax Planning and Controversy Defense Become Criminal Conduct” at the 71st Tulane Annual Tax Institute on November 17th, 2022.
Taxpayers frequently look to minimize their tax burdens or avoid immediate payment of tax liabilities and tax professionals often assist with a variety of planning structures or defensive strategies. It is when these structures or strategies cross the line that the Government sounds the alarm. On the civil side, tax-advantaged transactions or aggressive collection strategies that are “to good to be true,” “lack economic substance,” or “lack business purpose” can result in substantial civil penalties, professional licensing issues, and injunctions. When the Government believes that the individuals involved intentionally violated the rules – lying, cheating, or stealing – the matter can quickly move into the criminal realm. This panel will review what causes the Government to initiate a criminal tax investigation, the roles of IRS-CI, the Justice Department’s Tax Division, and the U.S. Attorney’s Office, the transactions and structures currently targeted by the IRS, and “ripped from the headlines” criminal tax prosecutions.
Click here to register.

Bryan C. Skarlatos Participates In A Panel Entitled "When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice" At The 81st Institute On Federal Taxation
2022-11-17 20:15 - 21:55 (America/New_York)
Bryan C. Skarlatos chairs a panel titled “When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice” on November 17, 2022 at the 81st Institute on Federal Taxation in San Diego, California.
Panel Description: How sure do you have to be before you tell a client it is okay to take a deduction or defer income? Do you have to audit a client’s records or can you just rely on what the client says? After the return has been filed, how do you handle an audit when you know the client’s tax return is wrong? What do you do if the information you submitted to the IRS is not accurate? When do you have to worry about conflicts of interest? While the answers to these questions may not always be clear, the law and related ethical standards provide very specific rules to help find the answers. This panel of expert practitioners addresses these and other thorny ethical issues that arise in everyday tax practice through the use of hypothetical examples. This program is essential for tax professionals who want to stay on the right side of the line.
Panelists:

Chair: Bryan C. Skarlatos, Esq., Partner, Kostelanetz LLP, New York, NY
Michael J. Desmond, Esq., Partner, Gibson, Dunn & Crutcher, Los Angeles, CA and Washington, DC
Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

Click here 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"
2022-11-18 13:15 - 14:15 (America/Chicago)
Megan L. Brackney participates in a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” on November 18, 2022 at the Practicing Law Institute’s Tax Strategies 2022 program.
Panel Description: Panelists discuss ethical rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit. Additionally, panelists describe the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Panelists:

Megan L. Brackney
Jenny L. Johnson
Bradley M. Seltzer

Click here for more information and to register.

Caroline D. Ciraolo Moderates A Panel Titled "From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime" At The 2022 IRS Representation Conference
2022-11-18 13:45 - 14:45 (America/New_York)
Caroline D. Ciraolo moderates a panel titled “From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime” at the 2022 IRS Representation Conference.
Panel Description: Audits of partnerships were previously governed by special procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). At the start of the 2018 tax year, partnership audits became governed by the new Centralized Partnership Audit Regime. The new regime is dramatically changing the way audits are handled and practitioners must understand the new rules to effectively represent their clients and avoid costly mistakes. This panel will discuss the differences between TEFRA and the BBA, and preparing for and effectively managing a partnership audit under the new rules.
Moderator:

Caroline D. Ciraolo, Esq., Kostelanetz LLP, Washington, DC

Panelists:

Philip J. Wilson, CPA, Marcum, LLP, Costa Mesa, CA
Steven Hurok, Esq., Citrin Cooperman & Company LLP, New York, NY
G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA

Click here to register. Please note the event will be taking place in ET time.

Megan L. Brackney Participates In A Tax Litigation And Controversy Panel At The WSTA-WSTEC 2022 Fall Tax Conference
2022-11-22 11:30 - 12:45 (America/New_York)
Megan L. Brackney participates in a tax litigation and controversy panel on November 22, 2022 at the 2022 Fall Tax Conference co-sponsored by the Wall Street Tax Association and the Wall Street Tax Educational Corporation.
Panel Description: Panelists discuss implications of the recent decision on agencies’ regulatory power as well as IRS notices and regulations subject to the APA notice-and-comment process.
Panelists:

Megan L. Brackney, Partner, Kostelanetz LLP
Miriam Fisher, Partner, Latham & Watkins LLP
Larry Hill, Partner, Steptoe & Johnson LLP

Moderator:

Kevin Salinger, Head of Tax Counsel & Advisory, Jefferies

Click here for more information

Bryan C. Skarlatos Presents On "Tax Ethics: Best Practices for Ensuring Compliance With Circular 230" At A Strafford Live Webinar
2022-11-22 13:00 - 14:50 (America/New_York)
Bryan C. Skarlatos presents on “Tax Ethics: Best Practices for Ensuring Compliance With Circular 230” on November 22, 2022 at a Strafford live webinar.
Panel Description:
This course discusses Circular 230 concerns regarding ethical encounters facing tax professionals, including how current norms impact the profession. The panel examines best practices to ensure compliance and avoid penalties.
Fulfilling one’s professional obligations as a tax practitioner has never been easy, and the disruption caused by more practitioners working from home compounds the profession’s ethical challenges. This webinar explores how Circular 230, statutory penalties, and other applicable rules apply in everyday situations and how technological changes expose tax professionals to potential sanctions.
To practice before the IRS, tax practitioners must comply with standards outlined in Circular 230, which covers conflicts of interest, the duty of confidentiality, knowledge of a client’s omission, and other issues, including the duty of supervisors to ensure that others in their firm comply with the rules. Knowing the requirements of Circular 230, which complements the professional standards adopted by accounting societies and bar associations, is vitally important.
Speaker:

Bryan C. Skarlatos, Esq., Kostelanetz LLP

Click here to register.

Caroline D. Ciraolo Participates In A Panel Titled "Tax Controversy" At The IFA USA 3rd Annual Winter Conference
2022-11-30 11:00 - 12:20 (America/New_York)
Caroline D. Ciraolo speaks about tax controversy at the IFA USA 3rd Annual Winter Conference on November 30, 2022.
Description:
This panel addresses current IRS enforcement efforts, dispute resolution procedures, and litigation of international tax issues. Particular attention is paid to recent transfer pricing cases and government-to-government resolution.
Moderator:

Steve Wrappe, Grant Thornton

Panelists:

Caroline D. Ciraolo, Kostelanetz LLP
Philip Baker, University of Oxford
Thomas Greenway, KPMG
James Kelly, IRS

Click here to register.
