Megan L. Brackney Presents On "Ethical Issues In Practice Before The IRS" For The CPA Academy
2023-07-11 11:00 - 12:00 (America/New_York)
On July 11, 2023, Megan L. Brackney presents a webinar on “Ethical Issues in Practice Before the IRS” for the CPA Academy.
Description: This session covers the provisions of Circular 230 and the AICPA Statements on Standards for Tax Services that apply when interacting with the IRS during audits, appeals, collection matters, and other circumstances. Megan L. Brackney discusses the duty to provide information to the IRS and prolong the proceedings, diligence as to the accuracy of information presented to the IRS, and reliance on clients for information. She also discusses the civil and criminal penalties that apply to practitioners who violate these standards.
Learning Objectives:

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

CPE credit may be offered for attendance.
Click here for more information and to register.

Caroline Ciraolo Appears On Tax Chat! Series On Transforming Tax Administration Entitled "IRS Penalty Policy and Practice" At The Center for Taxpayer Rights
2023-08-15 12:00 - 13:00 (America/New_York)
On August 15th, 2023, Caroline Ciraolo participates in a webinar panel titled “IRS Penalty Policy and Practice” as part of a webinar series titled “Transforming Tax Administration” presented by Center for Taxpayer Rights.
Description: Center for Taxpayer Rights presents a series of webinars from March 23, 2023 through August 31, 2023, titled Transforming Tax Administration. Each Tax Chat! touches on a separate topic.
If those interested already attended one of the Tax Chats! in this series, there’s no need to sign up again – a Zoom link will be sent via email. For those new to the series, you may sign up for the free online program here.
Panelists: Caroline Ciraolo of Kostelanetz LLP, Eric LoPresti of the US Senate Finance Committee, Susan Morgenstern of the Center for Taxpayer Rights, and Bob Probasco, Director of the Tax Dispute Resolution Clinic at Texas A&M University School of Law.

Heather Fincher Participates In A Webinar Entitled "Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies" For Strafford
2023-08-22 13:00 - 14:50 (America/New_York)
On August 22, 2023, Heather Fincher participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford. CPE Credit is offered for this event.
Description: This course provides tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact of IRS regulations requiring 5472 reporting by disregarded entities (DREs) with foreign owners. The panel provides line-by-line guidance on completing the form, defines complex concepts, and discusses the impact of IRS rules expanding filing requirements.
Panelists: Heather Fincher, Kostelanetz LLP and John Samtoy, Holthouse Carlin & Van Trigt LLP.
Click here for more information and to register.

Michael Sardar Participates In A Webinar Panel Titled "Nuts and Bolts of Tax Litigation: Administrative Process Summary, Choice of Forum, Initiating a Case" For The ABA Tax Section
2023-08-23 13:00 - 14:30 (America/New_York)
On August 23, 2023, Michael Sardar participates in a webinar panel titled “Nuts and Bolts of Tax Litigation: Administrative Process Summary, Choice of Forum, Initiating a Case” for the ABA Tax Section. CLE credit is offered for this event.
Description: This is the first of a four-part webinar series discussing the “nuts and bolts” of tax litigation. In this introductory webinar, the panelists provide an overview of the administrative process that precedes nearly all tax cases. The panelists also discuss where a case should be (or can be) filed and how to file it.
This webinar series is a partnership between the Tax Section’s Young Lawyers Forum and Court Procedure & Practice committee.
Panel Moderator: Ian Atkinson, Schonekas, Evans, McGoey & McEachin, L.L.C.
Panelists: Michael Sardar, Kostelanetz LLP; Jeffrey Glassman, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP; Fran Obeid, MFO Law, PC; Abbey Garber, Holland & Knight LLP; Aaron Esman, Moore Tax Law Group.
Click here for more information.

Jay R. Nanavati Participates On A Panel Titled "'The Art of the Deal' - Negotiating Plea Deals in Criminal Tax Cases" At The Summer Tax Summit
2023-08-29 08:10 - 09:00 (America/Chicago)
On August 29, 2023, Jay R. Nanavati participates on a panel titled “‘The Art of the Deal’ – Negotiating Plea Deals in Criminal Tax Cases” at the Summer Tax Summit presented by the St. Louis Chapter of the Federal Bar Association in St. Louis, MO. CLE credit is offered for this event.
Description: The panel will focus on the following topics: (1) the relationship between the IRS, U.S. Department of Justice, Tax Division, and local U.S. Attorney’s Offices in investigating and prosecuting criminal tax cases; (2) opportunities to seek early resolution in tax cases involving other potential white-collar crimes; (3) best practices for the “taxpayer conference” with DOJ Tax; (4) sentencing considerations and strategies; and (5) mitigating collateral civil consequences in criminal tax cases.
Panelists:

Jay R. Nanavati, Partner, Kostelanetz LLP
Anthony (“Tony”) Box, Partner, Gray Reed
Gwendolyn E. Carroll, Assistant United States Attorney and White-Collar Unit Supervisor, U.S. Attorney’s Office for the Eastern District of Missouri
Evan Davis, Partner, Hochman Salkin Toscher Perez P.C.,
Jeff Jensen, Partner, Husch Blackwell

Click here to register and for more information.

Garrett L. Brodeur Participates On A Panel Titled "Cryptocurrency - IRS Civil & Criminal Enforcement Trends" At The Summer Tax Summit
2023-08-29 09:10 - 10:00 (America/Chicago)
On August 29, 2023, Garrett L. Brodeur participates on a panel titled “Cryptocurrency – IRS Civil & Criminal Enforcement Trends” at the Summer Tax Summit presented by the St. Louis Chapter of the Federal Bar Association in St. Louis, MO. CLE credit is offered for this event.
Description: The panel discusses the latest IRS guidance and regulations regarding the tax treatment of cryptocurrency as well as the latest in IRS/DOJ civil and criminal enforcement trends related to cryptocurrency.
Panelists: Garrett L. Brodeur, Associate, Kostelanetz LLP; Sandy J. Boxerman, Shareholder, Capes Sokol; Travis W. Thompson, Associate, Sideman Bancroft LLP.
Click here to register and for more information.

Don Fort Participates In Interview Titled "IRS Enforcement Priorities" At The Summer Tax Summit
2023-08-29 12:20 - 13:10 (America/Chicago)
On August 29, 2023, Don Fort, Director of Investigations at Kostelanetz LLP, will participate in an interview with IRS-CI Chief Jim Lee titled “IRS Enforcement Priorities” at the Summer Tax Summit presented by the St. Louis Chapter of the Federal Bar Association in St. Louis, MO. CLE credit is offered for this event.
Description: The Chief of IRS Criminal Investigation (CI), Jim Lee, sits down for a fireside chat with his predecessor and former IRS CI Chief, Don Fort. The pair will discuss current criminal enforcement priorities of the IRS, technological innovations and data analytics used in criminal tax investigations, and how the increase in IRS funding will enhance the ability to pursue bad actors.
Panelists: Don Fort, Director of Investigations at Kostelanetz LLP, and Jim Lee, Chief of IRS Criminal Investigations
Click here to register and for more information.

William Greco Appears On “Nuts and Bolts of Tax Litigation” Webinar Series Panel Titled “Nuts and Bolts of Tax Litigation: Motion Practice” At the American Bar Association
2023-08-30 13:00 - 14:30 (America/New_York)
On August 30, 2023, William Greco participates in a webinar titled “Nuts and Bolts of Tax Litigation: Motion Practice” for the ABA Tax Section. CLE credit is offered for this event.
Description: This is the second of a four-part webinar series discussing the “nuts and bolts” of tax litigation. In this webinar, the panelists will discuss how to use, and respond to, motions successfully during a tax case.
This webinar series is a partnership between the Tax Section’s Young Lawyers Forum and Court Procedure & Practice committee.
Panel Moderator: Jamal Aquil, KPMG US LLP
Panelists: Lawrence A. Sannicandro, McCarter & English, LLP; William Greco, Kostelanetz LLP; Kandyce Jayasinghe, Covington & Burling LLP; Devin Hludzik, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP; Diana L. Leyden, Special Trial Judge, United States Tax Court.
Click here for more information and to register.

Don Fort Delivers A Keynote Address Titled "Embracing Integrity: Safeguarding Global Economies Against Economic Crime" At The 40th Cambridge International Symposium on Economic Crime
2023-09-03 18:30 (Europe/London)
On September 3, 2023, Don Fort delivers a Keynote Address titled “Embracing Integrity: Safeguarding Global Economies Against Economic Crime” at the opening dinner for the 40th Cambridge International Symposium on Economic Crime.
Click here for more information.

Caroline D. Ciraolo Delivers A Keynote Address Titled "The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement" At The 40th Cambridge International Symposium on Economic Crime
2023-09-05 08:00 (Europe/London)
On Tuesday, September 5th, 2023, Caroline D. Ciraolo presents a keynote address titled “The Role of U.S. Department of Justice, Tax Division in International Criminal Tax Enforcement” at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge.
Date: 8:00am BST (U.K. Time) on Tuesday September 5th, 2023.
A full program of events can be found here.

Don Fort Chairs A Panel And Plenary Workshop Titled “J5 - The Joint Chiefs of global tax enforcement" At The 40th Cambridge International Symposium on Economic Crime
2023-09-05 08:00 - 10:15 (America/New_York)
On September 5, 2023, Don Fort moderates a panel and plenary workshop titled “J5 – The Joint Chiefs of global tax enforcement” at the 40th Cambridge International Symposium on Economic Crime.
Description: The panel discusses international collaboration in fighting global economic crime.
Chairman: Don Fort, Director of Investigations, Kostelanetz LLP, Washington, DC
Panelists:

Simon York, former Director, HM Revenue and Customs, UK
Richard Las, Director, Fraud Investigation Service, HM Revenue and Customs, UK
John Ford, Deputy Commissioner, Integrated Compliance, Australian Taxation Office, Australia
James Lee, Chief, Criminal Investigations Internal Revenue Service, US Department of Treasury, Washington DC, USA
Niels Obbink, Director General, Fiscal Intelligence and Investigation Service, Netherlands
Eric Ferron, Director General, Criminal Investigations, Revenue Agency, Canada

Click here for more information.

Caroline D. Ciraolo Chairs Plenary Workshop At 40th Cambridge International Symposium on Economic Crime Titled "Aiding, abetting, and assisting - the facilitation of Tax Crimes"
2023-09-05 10:15 - 11:15 (America/New_York) | Jesus College, University of Cambridge
On Tuesday, September 5th, 2023, Caroline D. Ciraolo chairs a plenary workshop at the upcoming 40th International Symposium on Economic Crime, Jesus College, University of Cambridge. The workshop is titled “Aiding, abetting, and assisting – the facilitation of Tax Crimes” and is one of many sessions in the symposium.
Date: 4:15pm – 5:15 (U.K. Time) / 10:15am – 11:15pm (ET) on Tuesday, September 5th 2023
Panelists:
Caroline D. Ciraolo (Chair), Partner, Kostelanetz LLP [former Assistant Attorney General, Tax Division, U.S. Department of Justice, Washington, DC]
Sarah Paul, Partner, Co-Global Head of Corporate Crime and Investigations, Eversheds Sutherland, New York [former Assistant U.S. Attorney and Tax Coordinator, U.S. Attorney’s Office, Southern District of New York]
Polly Sprenger, Partner, Addleshaw Goddard LLP, London [former Head, Strategic Intelligence, Serious Fraud Office of England, Wales and Northern Ireland, UK]
Mary Hammond, Executive Director, Global Operations Policy and Support, Criminal Investigation, Internal Revenue Service
A full program of events can be found here.

Megan L. Brackney Participates In Ethics Panel At International Fiscal Association USA Virtual Conference
2023-09-13 08:00 - 17:00 (America/New_York)
Megan L. Brackney will participate in an Ethics panel at the 4th Annual International Fiscal Association USA Virtual Conference on September 13th, 2023. The conference will be held virtually, with several hours of substantive programming each day. Attendees may earn up to 1.5 hours of CLE Credit in Ethics for participating in select sessions. Additional CLE and CPE credit is available for attending sessions in different practice areas.
Panel Moderator:
Chris Rizek, Caplin & Drysdale
Panelists:
Megan L. Brackney, Kostelanetz LLP
Linda Galler, Hofstra University School of Law
Register here for the conference.

Garrett L. Brodeur Participates In A Webinar Titled "Nuts and Bolts of Tax Litigation: Trial and Pre- and Post-Trial Briefing" For The ABA Tax Section
2023-09-13 13:00 - 14:30 (America/New_York)
On September 13, 2023, Garrett L. Brodeur participates in a webinar titled “Nuts and Bolts of Tax Litigation: Trial and Pre- and Post-Trial Briefing” for the ABA Tax Section. CLE credit is offered for this event.
Description: This is the fourth of a four-part webinar series discussing the “nuts and bolts” of tax litigation. In this webinar, the panelists discuss strategies for successfully trying tax cases. The panelists also discuss how to effectively prepare pre- and post-trial briefs.
This webinar series is a partnership between the Tax Section’s Young Lawyers Forum and Court Procedure & Practice committee.
Panel Moderator: Fatima Garcia, IRS Office of Chief Counsel
Panelists: Garrett Brodeur, Kostelanetz LLP; Hon. Albert G. Lauber, United States Tax Court; Kelley Miller, Reed Smith LLP; Mitch Horowitz, Buchanan Ingersoll & Rooney PC; Eman Cuyler, Skadden, Arps, Slate, Meagher & Flom LLP.
Click here for more information and to register.

Tax Controversy – When The Line Is Crossed… (CLE)
2023-09-21 07:30 - 09:00 (America/Los_Angeles)
Caroline D. Ciraolo participates as the featured speaker in a webinar titled “Tax Controversy – When the Line is Crossed…” at the 2023-2024 Portland Virtual Tax Forum. This program offers CLE credit.
Speaker:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Click here for more information.

Claude M. Millman Participates On A Panel Entitled "Doing Business in New York" At the 2023 Government Procurement Conference
2023-09-21 10:30 - 11:30 (America/New_York)
Claude M. Millman participates on a panel entitled “Doing Business in New York” at the Government Procurement Conference on September 21, 2023 at The Museum of Jewish Heritage in New York.
Panel Description: PASSport and the Preferred Source Program are both committed to making New York’s contracting process, accessible and inclusive. This panel offers a detailed discussion about the New York procurement process and finding ways to succeed. What are the most effective strategies addressing today’s challenges? What are the best methods to winning the bidding process and making sense of various kinds of RFPs? Hear what NY government entities want from potential contractors and tips from the experts.
Moderator:

Keith L.T. Wright, Director of Strategic Planning, Government Relations Group, Davidoff Hutcher & Citron LLP

Panelists:

Claude M. Millman, Partner, Kostelanetz LLP
Lisa M. Flores, Director, Mayor’s Office of Contract Services
Roman Gofman, Assistant Commissioner, New York City Office of Citywide Procurement
Christopher Burke, Executive Director, New York State Preferred Source Program for New Yorkers Who are Blind (NYSPSP)

Click here for more information and to register.

Sharon L. McCarthy Participates In Panel Titled "Ethical Considerations for Corporate Investigations: Views from All Sides"
2023-10-04 14:00 - 17:00 (America/New_York)
Sharon L. McCarthy will participate in a panel titled “Ethical Considerations for Corporate Investigations: Views from All Sides” hosted by the New York City Bar Association at 2:00 – 5:00pm on October 4th, 2023. The panel will be conducted via webinar.
This annual update program will explore current issues and recent developments relating to ethical duties and responsibilities of attorneys in internal investigations involving corporations and other entities. These issues will be discussed from the point of view of company or entity counsel, counsel for current and former employees and counsel for government agencies. This year’s program will devote special attention to issues that arise in connection with joint defense agreements, including ethical obligations and conflicts arising from such agreements; ethics and pitfalls surrounding the use of artificial intelligence; the crime-fraud exception; and obligations to ensure and preserve client confidentiality, including scenarios arising from cyber incidents.
3.0 CLE Credits in Ethics (NY) and Professional Responsibility (NJ) are available for attending this event.
Program Chairs:
Frank Wohl, Lankler Siffert & Wohl, LLP
Jillian B. Berman, Lankler Siffert & Wohl, LLP
Panelists:
Sharon McCarthy, Kostelanetz LLP
Richard F. Albert, Morvillo Abramowitz Grand Iason & Anello PC
Professor Bruce A. Green, Fordham University School of Law
Randall Jackson, Willkie Farr & Gallagher LLP
Karen P. Seymour, Sullivan & Cromwell LLP
Negar Tekeei, Co-Chief, Narcotics Unit, U.S. Department of Justice
Registration begins on August 30th, 2023. Please visit here for registration details. Please visit the program guide for more information.

ABA Tax Section’s Virtual 2023 Fall Tax Meeting
2023-10-16 - 2023-10-20
Kostelanetz attorneys will participate in a variety of panels and presentations at the ABA Tax Section’s Virtual 2023 Fall Tax Meeting on October 16-20, 2023.
Tuesday, October 17, 2023
2:30 pm – 3:00 pm: Michael Sardar presents on International Tax Enforcement during the “Reports of Subcommittees on Important Developments” section of the meeting.
Panelists:

Michael Sardar, Partner, Kostelanetz LLP
Joshua Wu, Counsel, Latham & Watkins LLP
Damon Rowe, Partner, Meadows Collier Reed Cousins Crouch & Ungerman LLP

Thursday, October 19, 2023
3:15 pm – 4:00 pm: Don Fort moderates a panel titled “Big Data & Analytics – The Government’s Perspective.”
Description: The private sector has embraced AI to improve business operations and streamline costs, but the government has taken a different approach dependent on “big data” and sophisticated analytical tools. This panel features several IRS representatives, who will explain the ways data analytics have revolutionized fraud detection, civil and criminal case development, and customer service. CLE credit is offered for this event.
Moderator: Don Fort, Director of Investigations, Kostelanetz LLP
Panelists:

Melanie R. Krause, Chief Data and Analytics Officer, IRS;
Darrell J. Waldon, Executive Director, Advanced Analytics & Innovation, IRS-CI;
Benjamin Swartz, Acting Project Director – Strategic Operating Plan, IRS SB/SE

Learning Objectives: After attending the session, the participant will be able to:

Describe how Big Data and Data Analytics have modernized the IRS.
Describe specific analytical tools and methods used by IRS personnel.
Describe how the government’s use of data analytics is revolutionizing fraud detection, civil and criminal case development, and customer service.

Friday, October 20, 2023
10:30 am – 12:00 pm: Heather Fincher presents on a panel titled “Trick or Treaty: US Treaties and Interaction with Non-Treaty Tax Law.”
Description: The panel will address recent issues relating to US treaties, including (1) new US bilateral treaty developments (e.g., Chile, Croatia, Hungary); (2) the interaction of recent US legislation/regulation with US treaties (e.g., foreign tax credit regs); and (3) the interaction of recent non-US legislation/regulation with US treaties (e.g., extraterritorial taxes, Pillar 2). CLE credit is offered for this event.
Panelists:

Heather Fincher, Associate, Kostelanetz LLP;
Jeff Rubinger, Partner, Winston & Strawn LLP;
Doug Poms, Partner, KPMG
Elena S. Virgadamo, Deputy International Tax Counsel for Treaty Affairs, Office of Tax Policy, U.S. Department of the Treasury

12:30 pm – 2:00 pm: Megan L. Brackney presents on a panel titled “Accuracy-Related Penalties: Establishing Reasonable Cause in the Age of Social Media.”
Description: The growth of social media platforms like Tik Tok and Twitter have led taxpayers to increasingly turn to nontraditional sources of information to learn about tax laws. In this panel, we will explore that development in the context of civil penalties. To what extent can taxpayers who rely on social media to their detriment establish a valid reasonable cause defense to accuracy-related penalties? The initial reaction among tax professionals is that taxpayers rely on social media for tax advice at their own peril. But dig deeper, as this panel will, and the issue is a bit more nuanced. CLE credit is offered for this event.
Moderator: Jessica L. Jeane, VP of Tax Policy and Strategic Partnerships, Western CPE
Panelists:

Megan L. Brackney, Partner, Kostelanetz LLP
Jonathan T. Amitrano, Partner, Taylor, Nelson, Amitrano LLP
Professor Kathleen DeLaney Thomas, UNC School of Law

Learning Objectives: After attending the session, the participant will be able to:

Analyze the manner in which taxpayers obtain substantive tax advice via social media.
Review IRC § 6662 and 6663, and Treasury Regulation 1.6664-4(b)(1) as the current foundation for reasonable cause as a defense to accuracy-related penalties.
Review relevant case law that explores how taxpayers can establish reasonable cause as a defense to the imposition of accuracy-related penalties.
Understand how standards and principles set forth in regulations and case law may assist taxpayers in establishing reasonable cause in situations where taxpayers are acquiring substantive tax information via nontraditional ways, including social media.

4:30PM – 6:00PM: Abigail Burke moderates the “Women in Tax Forum (Non-CLE)”
Description: The Women in Tax Forum seeks to provide a community to empower, support, and celebrate women as they
build careers and lives that they love. The leaders of the Women in Tax Forum welcome members of the Tax Section to join them for an introductory session and virtual networking event. Following the introductory session, we will break into small groups to get to know the members of the community, discuss barriers we have observed for women in tax law, and explore ways to overcome those barriers. Attendees are asked to complete this survey to aid break-out group discussions.
Moderators:

Abigail Burke, Kostelanetz LLP
Darianne De Leon, Jones Day
Blair Hlinka, Trial Attorney, Department of Justice, Tax Division
Candice C. James, Ernst & Young
Sonia Shaikh, Miles & Stockbridge

Please visit here to register for this event. Please visit the ABA’s program guide for more information.

Michael Sardar Presents on International Tax Enforcement At The American Bar Association's Virtual 2023 Fall Tax Meeting
2023-10-17 14:30 - 15:00 (America/New_York)
Michael Sardar will give a presentation on International Tax Enforcement during the “Reports of Subcommittees on Important Developments” section of the American bar Association’s Virtual 2023 Fall Tax Meeting on October 17th, 2023.
Please visit here to register for this event. Please visit the ABA’s program guide for more information.

Ethical Considerations in Jury Trials
2023-10-18 13:45 - 14:45 (America/New_York)
Sharon L. McCarthy participates in a panel titled “Ethical Considerations in Jury Trials” hosted by the Practicing Law Institute at 1:45 pm on October 18th, 2023. The panel will be conducted online and in person. CLE credit is offered for this event.
Event Description:
The 1-day program titled “Trial by Jury 2023” will explore explore ethical consideration in jury trials. After completing this session participants will be able to avoid ethical pitfalls in the voir dire, ethically investigate jurors using social media, and understand ethical issues involved with using jury consultants and investigating jurors. The program features masters of the bar and the bench presenting valuable and useful insights on jury trials. The Practicing Law Institute has assembled the most experienced and respected state and federal judges, as well as many distinguished litigators, to give a unique view into jury trials and the best way to handle them, from opening statements through closing arguments. The panelists will also dissect the ethical issues that often arise and the best ways to handle these situations. Join to gain proven strategies and practical tools to successfully manage every phase of a jury case.
Panel Leader:
Antonina M. Apps, Regional Director of the New York Office of the United States Securities and Exchange Commission
Speakers:
Sharon L. McCarthy, Kostelanetz LLP
Hon. Eric R. Komitee, United States District Court Judge for the Eastern District of New York
Hon. Loretta A. Preska, United States District Court Judge for the Southern District of New York
Please visit here for registration details and the program guide.

From The Experts: Tax Controversy And Tax Litigation - Civil & Criminal Tax Update
2023-10-22 13:15 - 15:45 (America/New_York)
Megan L. Brackney will speak on a panel titled “From The Experts: Tax Controversy And Tax Litigation – Civil & Criminal Tax Update” at the 82nd Institute on Federal Taxation hosted by the New York University School of Professional Studies. The conference will take place at The Westin New York at Times Square, New York, NY on October 22-27, 2023.
Event 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. The panel covers a broad range of topics that impact tax compliance and tax litigation, including an examination of recent cases, investigations, and programs – including familiar areas such as Microcaptive Insurance Arrangements, Digital Assets, and Offshore Accounts and Foreign Information Reporting Penalties. The panel will also delve into hot new topics such as Monetized Installment Sales, Employee Retention Credits and Treaty Pension Benefits, many of which have come to the forefront of the attention of taxpayers and professionals alike from the flurry of IRS notices and explosion of taxpayer challenges to IRS guidance and regulations.
Chairs:
Sandra R. Brown, Esq., Principal, Hochman, Salkin, Toscher, Perez, PC, Beverly Hills, CA
Melissa L. Wiley, Esq., Partner, Lowenstein Sandler, Washington, D.C.
Panelists:
Megan L. Brackney, Esq., Partner, Kostelanetz LLP, New York, NY
Niles A. Elber, Esq., Member, caplin & Drysdale, Chartered, Washington, D.C.

Please visit here for program details.

The Corporate Transparency Act and Treasury's Beneficial Ownership Disclosure Rules
2023-10-24
On October 24, 2023, Jay R. Nanavati delivered a lecture on “The Corporate Transparency Act and Treasury’s Beneficial Ownership Disclosure Rules” to the Wilmington Tax Group at the University and Whist Club in Wilmington, Delaware.
Click here to learn more about the Wilmington Tax Group and click here to view the presentation slides.

Tax Court Updates
2023-10-26 11:10 - 11:50 (America/Los_Angeles)
Caroline D. Ciraolo participates in a panel titled “Tax Court Updates” at the UCLA Extension Tax Controversy Institute in Beverly Hills, CA.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Frank Agostino, Agostino & Agostino Associates, P.C., Hackensack, NJ
Chief Judge Kathleen Kerrigan, U.S. Tax Court
Drita Tonuzi, Deputy Chief Counsel (Operations), Office of Chief Counsel, IRS

Click here for more information and to register.

Criminal Tax, Parallel Investigations and Joint Investigations – When Two Worlds Collide
2023-10-26 16:40 - 17:30 (America/Los_Angeles)
Bryan C. Skarlatos will present on panel titled “Criminal Tax, Parallel Investigations and Joint Investigations – When Two Worlds Collide” at the 39th Annual Tax Controversy Conference at UCLA Extension on October 26th, 2023. The conference will be held in-person. The events are hosted at the Beverly Hills Hotel in Beverly Hills, CA.
Event Description:
UCLA Extension’s Annual Tax Controversy Conference is the preeminent conference exclusively dedicated to tax controversy and tax litigation. The conference provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience.
Moderator:
Evan J. Davis, Principal, Hochman Salkin Toscher Perez P.C.
Panelists:
Bryan C. Skarlatos, Partner, Kostelanetz LLP
Tyler R. Hatcher, Special Agent In Charge (CI), IRS
Lorraine Y. Yu, Deputy Area Counsel (CI), IRS

Click here for more information.

How Far Can You Go? Ethical And Penalty Issues In Everyday Tax Practice
2023-10-26 17:15 - 18:55 (America/New_York)
Bryan C. Skarlatos will chair and Michael Sardar will moderate a panel titled “How Far Can You Go? Ethical And Penalty Issues In Everyday Tax Practice” at the 82nd Institute on Federal Taxation hosted by the New York University School of Professional Studies. The conference will take place at the Westin New York at Times Square, New York, NY on October 22-27, 2023 and the Claremont Club & Spa in Berkeley, CA on November 12-17, 2023.
Event Description:
As a responsible tax practitioner, you must understand the ethical standards that apply to your conduct and what can trigger a penalty assessment against you or your clients. How sure do you have to be before you can tell a client it is okay to take a deduction or exclude income? Can you accept what a client tells you, or do you have to audit your client’s records? When can your clients be subject to penalties? How can you protect your clients and yourself? This panel of expert practitioners addresses these and other thorny ethical and penalty issues that arise in everyday tax practice through the use of hypothetical examples.
Chair:
Bryan C. Skarlatos, Esq., Partner, Kostelanetz LLP, New York, NY
Moderator:
Michael Sardar, Esq., Partner, Kostelanetz LLP, New York, NY
Panelist:
NY: S. Starling Marshall, Esq., Partner, Crowell and Moring, New York, NY
CA: Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez PC, Beverly Hills, CA

Click here for more information and program details.

Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know
2023-10-27 13:15 - 14:15 (America/New_York)
Megan L. Brackney 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 New York Conference hosted by the Practising Law Institute on Oct. 25-27, 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:
Megan Brackney, Partner, Kostelanetz & Fink, LLP, New York, NY
S. Starling Marshall, Partner, Crowell & Moring LLP, New York, NY
CLE Credit is available for this event.
Visit here for registration and event details.

Please Sir, Can I Have Some Moore
2023-10-27 13:15 - 14:15 (America/Chicago)
Caroline D. Ciraolo will participate in a webinar titled “Please Sir, Can I Have Some Moore” hosted by the Federal Bar Association Section on Taxation. This webinar will address the case of Moore v United States, pending in the U.S. Supreme Court, involving a constitutional challenge to the one-time Section 965 transition tax. The panelists will discuss the background and procedural history of the case, the arguments being raised by the parties and in numerous amicus briefs, and some of the consequences that will flow from the Court’s decision. The event takes place virtually on October 27, 2023 from 12pm-1pm EDT.
Panelists:
Caroline D. Ciraolo, Partner, Kostelanetz LLP
Alfred Battista, Georgetown Law Tax L.L.M.
Chris Whitcomb, KPMG, Managing Director – Tax Controversy and Dispute Resolution
Laura Williams, PWC, International Tax Principal
Visit here for event details.

Ethical and Penalty Standards in Tax Practice
2023-10-30
Bryan C. Skarlatos will guest lecture on “Ethical and Penalty Standards in Tax Practice” for a class on Taxes and Business Strategy at the Tuck School of Business of Dartmouth University on October 30th, 2023. The course objective is to develop a framework for understanding how taxes affect business decisions. The Tuck School of Business, one of three professional schools of Dartmouth College, was founded in 1900 as the world’s first graduate school of management.

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
