Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2024 New York City
2024-11-01 13:15 - 14:15 (America/New_York)
Kostelanetz LLP partner Bryan C. Skarlatos will speak at the Practicing Law Institute’s (PLI) three-day program, Tax Strategies 2024, which focuses on complex corporate tax issues and transactions. Bryan will participate in a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” with S. Starling Marshall on Friday, November 1 at 1:15 PM EST. This session will cover the ethical challenges that corporate tax advisors face during the tax planning process, discussing critical judicial doctrines and standards such as Circular 230, AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct. Attendees will gain insights into how to navigate ethical pitfalls and avoid malpractice while providing tax opinions to corporate clients.
Tax Strategies 2024 is designed for tax professionals specializing in corporate transactions, including M&A, reorganizations, joint ventures, and cross-border activity. The conference will take place in New York City from October 30 to November 1, 2024, with additional sessions scheduled for Chicago and Los Angeles later in the year. The event includes in-depth discussions on the tax impacts of corporate transactions, tax controversy issues, and the role of financial instruments in litigation. Virtual participation options are available for both the New York and Chicago programs.
You can learn more about Tax Strategies 2024 and register here.
Bryan C. Skarlatos is a tax controversy attorney with over 30 years of experience. He has been recognized by Super Lawyers as one of New York’s Top 100 lawyers and was named “Lawyer of the Year” for New York tax litigation for 2025. In addition to serving on the advisory board of NYU’s Institute on Federal Taxation, Bryan is an adjunct professor at NYU School of Law. He also founded the annual New York University Tax Controversy Forum. He is frequently retained by individual and corporate clients, as well as foreign and state governments, to provide expert testimony on tax penalties.

2024 Hawaii Tax Institute
2024-11-03 - 2024-11-07
Kostelanetz partner Caroline Ciraolo and Director of Investigations Don Fort participated in multiple panels at the 61st annual Hawaii Tax Institute, the largest tax and wealth transfer conference in the U.S. that takes place in Waikiki Beach in Honolulu.
The comprehensive five-day conference covers several aspects of wealth transfers, tax administration, estate and tax planning, and tax controversy as they pertain to high-net-worth individuals. You can learn more about the Hawaii Tax Institute here.
Caroline and/or Don participated in the following:
Monday, November 4, 1:30 PM – 2:15 PM: “Is the Tide Turning? Current Developments Regarding International Information Return Penalties and Ethical Considerations”
Caroline spoke on this panel covering recent developments in the international tax space concerning the often onerous civil penalties taxpayers face for failure to report their interests in certain foreign entities, assets, accounts, and transactions.
Tuesday, November 5, 6:30 AM – 7:45 AM: “Early Bird Bonus Session: Tax Treaties for the Wealth Transfer Professional”
Caroline spoke at this early morning panel covering the complex and often misunderstood areas of wealth transfer tax planning, reporting obligations, and tax enforcement that apply to foreign and dual residents who may be eligible for reduced tax rates or tax avoidance under tax treaties.
Tuesday, November 5, 11:00 AM – 11:45 AM: “How the IRS Is Changing and What to Expect in the Future”
Caroline moderated this panel, and Don joined other former and current IRS leaders to speak on the technological, personnel, and administrative changes that have occurred and are anticipated under the Inflation Reduction Act.
Wednesday, November 6, 2:30 PM – 3:20 PM: “Conducting Financial Investigations from Both Sides of the Aisle”
Don spoke on this panel alongside other former and current IRS leaders on both the defense and prosecution perspectives of criminal tax investigations and prosecutions. The panel
included a deep dive into methodologies, strategies, and techniques in complex financial investigations, ethical issues, and legal frameworks involved.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, serving as a neutral in alternative dispute resolutions, providing expert consultations and testimony, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions.
Don is the Director of Investigations at Kostelanetz LLP and the former Chief of the Internal Revenue Service’s Criminal Investigation Division. Having spent nearly 30 years in law enforcement for the federal government, Don has deep expertise in financial crimes and has an extensive network of connections both within the government and in private industry.

Kostelanetz Partner and Director of Investigations Participate in 61st Annual Hawaii Tax Institute
2024-11-03 - 2024-11-07
Partner Caroline Ciraolo and Director of Investigations Don Fort are members of the faculty for the 61st Annual Hawaii Tax Institute which takes place November 3-7 on the island of Oahu. This event provides unparalleled education and professional development opportunities delivered by a diverse and distinguished faculty of recognized tax and wealth transfer authorities with a positive approach to current and practical subjects. This event is designed for attorneys, accountants, financial planners, planned giving professionals, bank and trust administrators, insurance agents, elder law specialists, non-profit administrators, wealth management professionals, enrolled agents, educators, and others who would benefit from high-quality continuing education.
Caroline will participate in the following three Hawaii Tax Institute sessions:
Monday, November 4, 1:30 PM – 2:15 PM: Is the Tide Turning? Current Developments Regarding International Information Return Penalties and Ethical Considerations
Over the past decade, the IRS has assessed staggering civil penalties for failure to comply with international reporting obligations involving foreign financial accounts and taxpayers’ interest in, and transactions with, foreign entities and trusts. After years of challenging these penalties with only limited success, taxpayers are achieving relief through litigation and, more recently, administrative appeals. This session will discuss the current developments, trends, and best practices in addressing non-compliance and related penalties in the international tax space.
Tuesday, November 5, 6:30 AM – 7:45 AM: Tax Treaties for the Wealth Transfer Professional
The United States has income tax and wealth transfer tax treaties with a number of foreign countries. Under these treaties, residents (not necessarily citizens) of foreign countries may be eligible to be taxed at a reduced rate, minimize wealth transfer taxation, and avoid double taxation that can arise when two countries both have the right to tax a decedent/taxpayer. Learn about this fascinating and usually misunderstood area of wealth transfer taxation and planning.
Tuesday, November 5, 11 AM – 11:45 AM: How the IRS Is Changing and What to Expect in the Future
Explore from behind the scenes, how the IRS is changing, who and what areas the IRS is currently focusing on, how the IRS is using technology, social media and artificial intelligence and what to expect in the future. This fascinating session will discuss and provide valuable information to all Wealth Transfer Advisor so they can better advise and protect their clients.
Don will participate in the following two Hawaii Tax Institute sessions:
Tuesday, November 5, 11 AM – 11:45 AM: How the IRS Is Changing and What to Expect in the Future
Explore from behind the scenes, how the IRS is changing, who and what areas the IRS is currently focusing on, how the IRS is using technology, social media and artificial intelligence and what to expect in the future. This fascinating session will discuss and provide valuable information to all Wealth Transfer Advisor so they can better advise and protect their clients.
Wednesday, November 6, 2:30 PM – 3:20 PM: Conducting Financial Investigations from Both Sides of the Aisle
This session will provide a comprehensive overview of methodologies, strategies, and techniques in conducting financial investigations from both the prosecution (government) and defense perspectives. The discussion will encompass a detailed examination of the distinct approaches utilized by each side. Learn from the prosecution standpoint, how the focus is on gathering irrefutable evidence through methods such as forensic accounting, data analysis, and legal instruments like subpoenas and search warrants, all while adhering to strict legal standards and ensuring evidence integrity. Discover conversely, how the defense aims to protect the client’s rights by critically analyzing the prosecution’s evidence, identifying procedural errors, and conducting independent forensic analyses to uncover exculpatory information. Understand that both perspectives require a deep understanding of financial systems, legal frameworks, and ethical considerations, as well as the ability to collaborate with a multidisciplinary team of experts to achieve a thorough and balanced investigation.

Tax Enforcement Trends: What’s Hot and What’s Not
2024-11-08 10:15 - 11:05 (America/New_York) | Mohegan Sun Resort & Casino, 1 Mohegan Sun Blvd., Uncasville, CT, 06382, United States
Kostelanetz partner Christopher Ferguson will speak at the IRS Representation Conference on November 8, 2024. He is a panelist for the session “Enforcement Trends: What’s Hot and What’s Not” that will be held from 10:15 AM to 11:05 AM Eastern.
The panel will cover a variety of tax enforcement topics, such as the IRS’s efforts with respect to the Employee Retention Credit, cryptocurrency, payroll tax debt, high net worth non-filers, and other hot issues. The panel will also cover what practitioners can expect in examinations, collections, and criminal tax investigations in 2025.
The New England IRS Representation Conference will be held November 7-8, 2024, at the Mohegan Sun Resort and Casino in Uncasville, CT. Ten hours of continuing education credit, including one hour of ethics, can be earned by attending the event. Virtual attendance options are available. You can learn more about the conference here.
Chris has over two decades of experience as a litigator, concentrating his practice on white-collar criminal defense as well as civil tax controversies, criminal tax fraud, and other regulatory enforcement matters. Chris also has extensive experience handling complex civil litigation and internal investigations.
CLE credit is available for this event.

The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil
2024-11-12 13:50 - 15:30 (America/Los_Angeles)
Kostelanetz LLP partner Michael Sardar will lead a session at the 2024 Taxpayer Representation Super Conference, hosted by the American Society of Tax Problem Solvers (ASTPS), from November 12-14, 2024, at Embassy Suites San Antonio Riverwalk. Michael’s session, “The Difficult Audit: Navigating Large Adjustments and Keeping Them Civil,” on November 12 from 1:50 pm to 3:30 pm will focus on managing risk in large and complex IRS audits, where large adjustments are likely. He will guide attendees through strategies for preserving clients’ privileges during sensitive audits, recognizing signs that an audit could escalate to a criminal investigation and ensuring clients remain compliant with their tax reporting obligations.
The Super Conference, a three-day event dedicated to representing clients before the IRS, features 15 sessions on high-level tax resolution topics. Attendees, including practitioners who focus on criminal and civil tax matters, white-collar criminal defense and government investigations, and tax controversy, will learn about issues ranging from criminal tax investigations to tax controversy litigation.
As IRS enforcement is expected to increase in 2025, the conference provides timely insights. Other notable sessions include how to file a protest letter to appeal denied Offers in Compromise, the IRS’s use of AI in auditing high-income taxpayers, and strategies for handling cases led by newly hired IRS agents.
You can learn more about the ASTPS Super Conference and register here. While live attendance in San Antonio is currently waitlisted, virtual attendance options are still available.
Michael Sardar is an experienced tax attorney and co-chair of the Federal Bar Association’s section on taxation’s New York chapter. Michael has vast experience in IRS foreign bank and asset reporting (FBAR) requirements and the IRS Offshore Voluntary Disclosure Program. He represents a variety of clients in civil and criminal tax investigations and prosecutions and other white-collar criminal matters in New York State and New York City.

"Winning Business in New York" panel during City & State New York’s Government Procurement Conference
2024-11-14 10:45 - 11:40 (America/New_York)
On November 14th, 2024, Usman Mohammad will be speaking on a panel titled, “Winning Business in New York,” during City & State New York’s Government Procurement Conference: Optimizing Costs, Mitigating Risks, & Enabling Business Growth. The Government Procurement Conference will foster business partnerships between the city and state level government, prime contractors, and small, minority, service-disabled veteran-owned, veteran-owned, and women-owned businesses.
Panel Description:
This panel offers a detailed discussion about the New York procurement process and finding ways to succeed. What are the most effective strategies addressing challenges including the possibility of an economic downturn, methods to winning the bidding process, and making sense of various kinds of RFPs, plus you will hear what NY government entities want from potential contractors.
Moderator:

Carlo Scissura, President, New York Building Congress

Panelists:

Usman Mohammad, Counsel, Kostelanetz LLP
Roman Gofman, Deputy Commissioner, NYC Office of Citywide Procurement
Lisette Camilo, Chief Administrative Officer, Metropolitan Transit Authority
Marc Hiller, General Counsel and Director of Procurement Services, Ostroff Associates, Inc.

Additional information on the event, including registration, is available here.

Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know (CLE)
2024-11-15 13:15 - 14:15 (America/Chicago)
On November 15, 2024, Megan L. Brackney will co-moderate a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” as part of the Practising Law Institute’s “Tax Strategies 2024 – Chicago” programming. Attendees will receive the latest information, strategies, and practical insights available from leading tax practitioners across the United States, along with policymakers from the IRS and the Department of the Treasury.
Course 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.

Moderators:

Megan L. Brackney, Kostelanetz LLP, New York City
Jennifer E. Breen, Morgan, Lewis & Bockius, Washington, D.C.

For full program details and registration information, please click here.
CLE credit is available for this event.

Ethics in Tax: Standards for Tax Advice
2024-11-21 09:00 - 09:55 (America/Los_Angeles)
Kostelanetz LLP partner Megan L. Brackney will kick off the Committee of Banking Institutions on Taxation (CBIT) 2024 Fall Tax Day with a session on November 21, 2024, from 9:00-9:55 AM on ethical standards for dispensing tax advice. Known for her extensive knowledge of tax ethics, Megan regularly educates other tax professionals on how to navigate the complexities of ethical issues in tax practice. Her session will be a valuable opportunity to explore current tax challenges while ensuring adherence to the highest ethical standards.
Fall Tax Day will take place at Arno Ristorante in New York City. The event begins at 8:45 AM and includes a full day of sessions covering topics like tax reporting regulations for digital assets, capital gains reporting, among other types of gains, and foreign trusts. Speakers from other prestigious firms such as PwC, Wolters Kluwer, and KPMG will join, along with insights from government professionals.
The cost to attend is $75 for CBIT Education members and $125 for non-members, with discounted rates available for members’ guests. Tax students and public service professionals may be eligible for waived registration fees. A cocktail reception at 4:30 PM concludes the day’s events.
You can learn more about CBIT’s 2024 Fall Tax Day and register here.
Partner Megan L. Brackney is an experienced tax attorney, Chair-Elect of the American Bar Association Section of Taxation, and an adjunct professor at New York University School of Law. Megan is also former Assistant U.S. Attorney for the Southern District of New York and a frequent speaker and contributor at local and national conferences on taxation, ethics in tax practice, penalties, and tax controversy.

ABA 2024 Criminal Tax Fraud and Tax Controversy Conference
2024-12-12 - 2024-12-14
Kostelanetz attorneys will be speaking on various panels at the American Bar Association’s 2024 Criminal Tax Fraud and Tax Controversy Conference, which is being held from Dec. 12-14, 2024, in Las Vegas.
Our lawyers will demonstrate their experience and knowhow on topics ranging from defense of high-wealth taxpayers and ethical considerations in criminal tax investigations to the current state of the IRS Voluntary Disclosure Program, the legal landscape for Syndicated Conservation Easements, and how the legal profession can promote diversity in its ranks.
Attendees can earn CLE credit throughout the conference. The full conference is eligible for 14.75 hours of CLE in 60-minute states (17.70 in 50-minute states like New York). The conference website can be found here.
Please join us for the following panels.

Friday, Dec. 13 — 9:15 AM – 10:15 AM
Defending High-Wealth Taxpayers In Civil And Criminal Tax Enforcement
Partner Bryan Skarlatos will participate in a panel of highly experienced practitioners who will address how to be ready for the substantive and procedural issues that may arise in enforcement cases against high-wealth taxpayers, including a discussion of the importance of understanding the bigger picture in which a high-wealth client may operate. The IRS has identified these types of cases as an enforcement priority.
Other participants include moderator Charles P. Rettig, Chamberlain Hrdlicka, and panelists Sheri Dillon, Morgan, Lewis & Bockius LLP; Charles Hodges, Jones Day; and Matthew Lerner, Sidley Austin LLP.

Friday, Dec. 13 — 11:30 AM – 12:30 PM
How Not To Be A Witness Against Your Client: Ethical And Other Considerations In Criminal Tax Investigations (Ethics CLE)
Partner Jay Nanavati will participate in a panel that will explore questions such as, what happens if your proffer in a criminal investigation turns out to be based on erroneous information from your client? What do you do when the grand jury subpoena calls for the client’s records, but those records are, in fact, fraudulent? The panel will discuss how to avoid these pitfalls and the ethical issues that arise when difficult choices must be made.
Other participants include moderator Patricia A. Pileggi, ArentFox Schiff, and panelists Tino Lisella, Carlton Fields; Jeffrey Neiman, Marcus Neiman & Rashbaum LLP; and Rod Rosenstein, King & Spalding LLP.

Friday, December 13 — 1:45 PM – 2:45 PM
Voluntary Disclosure: Where Are We Now?
Partner Michael Sardar will participate in a panel addressing the current state of voluntary disclosure programs and their effectiveness in aiding clients with tax compliance. The discussion will cover the evolution of these programs, the future of silent disclosures, and recent changes to the IRS’s voluntary disclosure practice. The panel will also share strategies on how to assist taxpayers in navigating the revised IRS Voluntary Disclosure Practice.
Other participants include moderator Larry Campagna, Chamberlain Hrdlicka, and speakers Dan Price, Law Offices of Daniel N. Price; and Zhanna Ziering, Moore Tax Law Group.

Friday, Dec. 13 — 5:00 PM – 6:00 PM
How The Legal Community Can Focus On Diversity Within Firms And In Service To Our Clients (Elimination of Bias CLE)
Partner Caroline Ciraolo will moderate a panel discussion on the importance of diversity and inclusion within law firms and the legal profession, so that firms can better assist clients in addressing their needs in navigating challenges in addressing their tax issues. Diversity comes in many forms, including national or cultural origin and visible and nonvisible health and physical limitations, as well as more commonly recognized differences in race, gender, sexual identity, sexual orientation, and myriad others. This panel will address how to be more aware of diversity challenges, including, as examples, language or physical barriers, and what resources are available at the IRS and Tax Court to help lawyers meet these challenges. The panel will be introduced by Kostelanetz associate Abigail Burke.
Other participants include panelists Erin M. Collins, National Taxpayer Advocate, IRS Taxpayer Advocate Service; Hon. Maurice B. Foley, Judge, United States Tax Court; and Michael Eddison Romero, Taylor Nelson Amitrano LLP.

Saturday, Dec. 14 — 11:00 AM – 12:00 PM
Conservation Easements: The Year In Review, And What To Expect
Partner Andy Steigleder will moderate a panel on the IRS’s continued focus on conservation easement issues. We have seen criminal and civil trials, with more to come. The panel will discuss key decisions over the past year and what is likely on the horizon.
Other participants include speakers Niles A. Elber, Caplin & Drysdale; Brian Gardner, Asbury Law Firm; Sarah Green, Dentons; Byung Hyuk (Billy) Min, Agostino & Associates P.C.; Carneil Wilson, Dentons.

Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know (CLE)
2024-12-13 13:15 - 14:15 (America/Los_Angeles)
On December 13, 2024, Andrew Weiner will co-moderate a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” as part of the Practising Law Institute’s “Tax Strategies 2024 – Los Angeles” programming. Attendees will receive the latest information, strategies, and practical insights available from leading tax practitioners across the United States, along with policymakers from the IRS and the Department of the Treasury.
Course 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.

Moderators:

Andrew Weiner, Kostelanetz LLP, Washington, D.C.
Chad D. Nardiello, Nardiello Turanchik Tompkins LLP, Los Angeles

For full program details and registration information, please click here.
CLE credit is available for this event.

Forms 5471 and 5472: Meeting the Substantially Complete Standards
2025-01-07
Kostelanetz partner Michael Sardar participates in an international tax compliance webinar through continuing educator provider Strafford on January 7, 2025. The recorded session is available for purchase.
The session, titled “Forms 5471 and 5472: Meeting the Substantially Complete Standards,” covers best practices for meeting the substantially complete standard in filling out Forms 5471 and 5472 for clients with any international ownership. These two IRS forms are among the most complex information returns that tax practitioners come across. They are also crucial information returns in international tax compliance.
Because these forms require information that can be subject to change frequently, it is very easy for oversight mistakes to occur. Therefore, Forms 5471 and 5472 are often deemed incomplete by the IRS, which can result in steep penalties. Learning how to correctly and substantially complete Forms 5471 and 5472 is critical for entities with one or more foreign owners or any other offshore ownership that could mandate the filing of these forms.
You can learn more about the webinar and purchase the recording here.
Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.

Defending Your Client in the Age of Fraud Enforcement: 2025 International Tax Conference Session
2025-01-09 - 2025-01-10
Kostelanetz partner Caroline Ciraolo is a speaker at the 2025 International Tax Conference taking place January 9-10, 2025, in Miami, Florida.
Caroline’s session, “Defending Your Client in the Age of Fraud Enforcement,” covers tax defense strategies for clients with cross-border activity in the wake of ramped-up IRS enforcement activity. She is presenting with Jeffrey Neiman, a founding partner of Marcus Neiman Rashbaum & Pineiro LLP.
The ITC is sponsored by the Florida Bar Tax Section and the Florida Institute of Certified Public Accountants. The conference is designed for tax professionals who focus on international taxation planning and compliance, international tax controversies, and managing multinational clients’ needs.
CLE credit is available. You can learn more about the conference here.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

2025 D.C. Bar Tax Conference
2025-01-15 - 2025-01-16
Kostelanetz partner Caroline Ciraolo is co-chair of the 2025 D.C. Bar Tax Conference and is speaking along with several other Kostelanetz attorneys, demonstrating the firm’s experience in federal tax controversy, partnership taxation, and constitutional and administrative law.
Kostelanetz is a Gold+ sponsor of the 2025 D.C. Bar Tax Conference, which is taking place January 15-16, 2025, at the District of Columbia Bar headquarters in Washington, D.C. In addition to the Kostelanetz attorneys, participants include IRS Commissioner Danny Werfel, Treasury Deputy Assistant Secretary of International Tax Affairs Scott Levine, and National Taxpayer Advocate Erin Collins. You can learn more about the conference and register here.
Please join us for the following panels:

Wednesday, January 15, 2025, 2:30 p.m. to 3:40 p.m.
Partnership Taxation/Tax Controversy: BBA Audits
Kostelanetz attorney Macdonald “Mac” Norman will participate in a panel of experienced practitioners with significant experience in partnership taxation matters. The panel will cover tax controversy issues that arise under the audit and tax collection procedures for partnerships under the Bipartisan Budget Act of 2015 (BBA).
Other participants include Rochelle Hodes, principal of Crowe LLP; Miri Forster, partner and tax controversy leader of Eisner Advisory Group LLC; Clifford Scherwinksi, Director of Pass-Through Entities at the IRS’ Large Business and International division; and Mary Slonina, managing director of KPMG US.

Wednesday, January 15, 2025, 4:30 p.m. to 5:00 p.m.
A Conversation with Erin Collins, National Taxpayer Advocate
Caroline Ciraolo will interview the National Taxpayer Advocate, Erin Collins, discussing contemporary tax administration issues and tax controversies.

Thursday, January 16, 2025, 12:55 p.m. to 1:55 p.m.
Supreme Court Update Panel
Kostelanetz attorney Andy Weiner will moderate a panel of experienced professionals on recent Supreme Court opinions affecting tax practice and what may be in store in the Court’s current term.
Other participants include Keith Fogg, professor emeritus at Harvard Law School; Dan Geyser, a partner of Haynes and Boone LLP; Luke McCloud, a partner of Williams & Connolly LLP; and Rachel Miller-Ziegler, a partner of Munger, Tolles, & Olson LLP.

Thursday, January 16, 2025, 2:15 p.m. to 3:15 p.m.
Tax Controversy: Tax Litigation Update
Caroline Ciraolo will moderate a panel of experienced professionals discussing notable tax litigation outcomes in 2024 and what legal professionals can expect in 2025.
Other participants include Justin Campolieta, partner of Jones Day; Lindsay Clayton, Assistant Chief of the Tax Division at the Department of Justice; Lisandra Ortiz, member of Miller & Chevalier Chartered; and Andrew Strelka, counsel at Latham & Watkins LLP.

Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on civil and criminal tax controversies at both the federal and state levels, including representing clients in sensitive audits, administrative appeals, litigation, criminal tax investigations, and prosecutions. Caroline also has extensive experience providing tax advice, conducting internal investigations, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has argued approximately 50 tax cases in the U.S. courts of appeals. He is a fellow of the American College of Tax Counsel and a Forbes contributor on tax controversy and policy issues.
Mac focuses his practice on U.S. federal income tax litigation matters, and he has broad experience in transactional work and international tax planning.

Innocent Spouse Relief for Federal Taxes and Penalties (CLE)
2025-01-27 18:00 (America/New_York)
Megan L. Brackney will present “Understanding the Innocent Spouse Defense” for the Matrimonial and Family Law Committee of the New York Women’s Bar Association on Jan. 27, 2025.
The program will explain the fundamentals of the Innocent Spouse relief for federal taxes and penalties. According to the IRS, “Innocent spouse relief can relieve you from paying additional taxes if your spouse understated taxes due on your joint tax return and you didn’t know about the errors.”
Megan will explore the complex issues that can sometimes accompany tax controversy cases involving Innocent Spouse defenses and claims for relief. This program will be useful to matrimonial attorneys as well as attorneys wishing to deepen their understanding of the intersection between matrimonial and tax law.
More information and registration for this event can be found here.
RSVPs requested by Jan. 24, 2025. CLE credit is offered for this course.
The program is free for members of the New York Women’s Bar Association (NYWBA) and members of the Women’s Bar Association of The State Of New York (WBASNY). The cost is $25 for all others.
The New York Women’s Bar Association is a non-profit organization dedicated to “improving the status of women in society, educating women lawyers and assisting them in professional development and advancement, and promoting the fair and equal administration of justice,” according to the NYWBA website. The NYWBA aims to accomplish its goals through the work of its committees, the presentation of continuing legal education programs, and the evaluation of judicial candidates. It is affiliated with the Women’s Bar Association of the State of New York (WBASNY).
Location: Kostelanetz LLP, 7 World Trade Center, 34th Floor, New York, New York 10007

Preparing for Estate and Gift Tax Audits
2025-02-13 12:00 - 13:45 (America/New_York)
Kostelanetz partner Melissa Wiley will speak at the Howard County (Md.) Estate Planning Council (EPC) membership lunch meeting on February 13, 2025. The panel presentation will address the steps that estate planning practitioners can take to minimize the chance or impact of gift and estate tax audits at the federal and state levels in Maryland, particularly in light of the potential sunsetting of provisions in the Tax Cuts and Jobs Act and the Maryland Comptroller’s office’s latest efforts to investigate Maryland estate tax returns.
The panel also includes Patrick Guthrie, director of business development at Evergreen Advisors, and Amanda Abel, manager of the Estate and NRS Tax Units of the Revenue Administration Division of the Comptroller of Maryland. The lunch will take place from 12 PM to 1:45 PM at Cured 18th and 21st, 10980 Grantchester Way #110, Columbia, Md. You can learn more and register here.
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities, including in the estate and gift tax arena. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

Cross-Border Real Estate Investments
2025-02-17 - 2025-02-18
Counsel Eduardo Cukier will speak at the 2025 International Tax Conference hosted by the University of San Diego School of Law and Chamberlain Hrdlicka Law Firm.
Eduardo’s panel, “Cross-Border Real Estate Investments,” will be held on Tuesday, February 18, from 11:15 a.m. to 12:05 p.m. The panel will discuss U.S. and Mexican tax and other considerations of cross-border real estate investments between the U.S. and Mexico. Eduardo will be joined by Patrick W. Martin of Chamberlain Hrdlicka and Rodrigo Adam of HgL Asesores.
The 2025 International Tax Conference will be held at Centro Internacional de Congresos (CIC) in Mérida, Yucatán, México on February 17-18, 2025. Sessions and panels will cover a variety of business, personal, and fiduciary cross-border taxation issues such as cross-border financing, international tax controversies, foreign tax credits, tax treaty considerations, and more. Kostelanetz partner Caroline Ciraolo is also a member of the International Tax Conference’s advisory board.
You can learn more about the conference and register here.
Eduardo focuses his practice on international tax issues concerning multinational businesses and high-net-worth clients. Having many years of experience with taxation and legal frameworks in both the U.S. and Latin America, Eduardo works with both domestic and multinational clients from a wide range of industries on foreign and domestic mergers and acquisitions, business restructuring, and cross-border litigation.

2025 ABA Tax Section Mid-Year Meeting
2025-02-19 - 2025-02-21
Kostelanetz attorneys Michael Sardar, Bryan Skarlatos, and Andy Weiner will speak on various panels of the ABA Tax Section Mid-Year Meeting, of which Kostelanetz is a Diamond sponsor. Our attorneys will demonstrate their knowledge and experience in international tax controversies and other international taxation matters, criminal tax cases, refund litigation, and more.
The ABA Tax Section Mid-Year Meeting will be held February 19-21, 2025, at the JW Marriott LA LIVE event center in downtown Los Angeles. The conference covers a large array of tax law topics and updates from the nation’s leading tax attorneys and authorities. You can learn more about the event and register here.
Please join us for the following panels:
Thursday, February 20, 2025, 10:00 a.m. to 11:45 a.m.
Cross-Functional Current Developments – Part II
Kostelanetz partner Bryan Skarlatos will participate in a panel in the conference’s Corporate & International Track discussing the latest regulatory and case law developments in corporate and individual international taxation. The panel will cover contemporary international tax issues, transfer pricing, and the increasing relevance of the economic substance doctrine in the U.S.
Other participants include Hans Gerling of KPMG; Professor Adam M. Katz of Seton Hall University School of Law; Loren Ponds of Skadden; and Jennifer R. Noel of ChristianaCare, who is moderating the panel.
Friday, February 21, 2025, 8:30 a.m. to 10:15 a.m.
Hot Topics and Common Pitfalls in Refund Litigation
Kostelanetz counsel Andy Weiner joins a panel that will explore the complexities of refund litigation for the conference’s Controversy Track. Panelists will discuss the considerations practitioners must make, and pitfalls they are likely to encounter, in litigating claims for refunds and abatements. Current refund litigation trends will also be discussed, including claims made under the Employee Retention Credit.
Other panelists include Melissa Briggs of Hochman Salkin Toscher Perez P.C.; Jeff Glassman of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP; Gavin Greene from the U.S. Attorney’s Office for the Central District of California; and M. Blair Hlinka of Caplin and Drysdale, Chartered, who is moderating the panel.
Friday, February 21, 2025, 10:30 a.m. to 12:15 p.m.
Keeping it Civil: How to Prevent a Civil Matter from Turning Criminal
Kostelanetz partner Michael Sardar will moderate a panel for the conference’s Controversy Track, discussing how to identify civil tax cases that could potentially become criminal matters. The panel will discuss criteria that often trigger criminal referrals, ethical considerations and strategies for such situations, and common pitfalls that practitioners face when civil matters are at risk of becoming criminal.
Other participants include Jenny C. Lin of Lin Tax Law; John Marston of Sheppard Mullin; Richard Westling of Epstein, Becker & Green, P.C.; and Zhanna A. Ziering of Moore Tax Law Group LLC.
For more than thirty-five years, Bryan has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice.
Michael has extensive experience on a wide range of tax controversy and white-collar criminal defense matters. Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors.
Andy focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. He is also a fellow of the American College of Tax Counsel, and a frequent writer and speaker on tax issues.

IRS Administrative Affairs: Current Developments and Reading the Tea Leaves in Tax Enforcement
2025-02-26
On February 26, 2025, Caroline Ciraolo will speak to Tax Executives Institute’s Detroit Chapter in Levonia, Michigan, about civil tax controversies, including current developments and expectations for tax enforcement in 2025 and beyond. Caroline will present with David Lee with National Tax Controversy Services, Deloitte LLP, who will address IRS administrative affairs and issues facing domestic and multinational entities, including transfer pricing.
Other panelists presenting to the TEI Detroit Chapter on topics including U.S. trade policies include Becky Allen LCB CUSECO, Senior Manager, Global Trade Advisory, Deloitte LLP, and David Reichow, Managing Director, Global Transfer Pricing, Deloitte LLP.
Two hours of CPE credit is available for this program.
Click here for more information and to register. Registration ends at 6 p.m. Thursday, February 20, 2025.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

49th Annual Federal Bar Association Tax Law Conference
2025-02-27 - 2025-03-03
Kostelanetz attorneys Michael Sardar, Melissa Wiley, Andy Weiner, and Will Greco will participate on various panels at the 49th Annual Federal Bar Association Tax Law Conference, of which Kostelanetz is a proud sponsor. Kostelanetz partner Caroline Ciraolo will make keynote remarks at the March 3 luncheon.
During the conference, our attorneys will demonstrate their knowledge and experience in ethical issues in taxation, criminal tax matters, navigating tax administration in a post-Chevron and post-Jarkesy landscape, and more.
Virtual portions of the Federal Bar Association Tax Law Conference will be held February 27-28, 2025. In-person sessions will be held on March 3, 2025, at the Ronald Reagan Building & International Trade Center in Washington, D.C. You can learn more about the conference and register here.
Please join us for the following panels:
Thursday, February 27, 2025, 11:00 a.m. to 12:00 p.m. (Virtual Only, Zoom)
Update on Ethical Issues in Taxation and Circular 230
Kostelanetz attorney Melissa Wiley will participate in a panel of experienced practitioners who focus on ethics and conflicts of interest in federal taxation matters. The panel will cover ethical considerations and responsibilities in light of updates to ABA model rules, state bar rules, and other standards that affect practitioners.
Other participants include Christopher Whitcomb, managing director of KPMG LLP, and Matthew Cooper, principal at Deloitte Tax LLP, who is also moderating the panel.
Thursday, February 27, 2025, 12:30 p.m. to 1:30 p.m. (Virtual Only, Zoom)
Developments in Penalty Controversy and Litigation
Kostelanetz attorney Will Greco will participate in a panel covering important developments in (1) IRS practice in the assertion of penalties, including automatic assessment, transfer pricing, economic substance and excessive refund penalties and (2) litigation regarding various penalties, including Farhy limitations on the assessment of certain penalties, 8th Amendment limitations on FBAR and potentially other penalties, and Jarkesy and 7th Amendment considerations in the tax penalty context.
Other participants include Joy Williamson, partner at Baker & McKenzie LLP, and Ed Froelich, counsel at McDermott Will & Emery, who is also moderating the panel.
Monday, March 3, 2025, 10:45 a.m. to 11:45 a.m. (In Person Only)
What Tax Lawyers Need to Know About the APA in Our New Post-Chevron World
Kostelanetz attorney Andy Weiner will moderate a panel discussing the potential impacts of the Loper Bright Supreme Court case on tax law. Participants will discuss the background of Loper Bright and the APA, what practitioners can expect for various tax rules’ levels of deference post-Chevron, and how Congress can delegate authority.
Other participants include David Foster, partner at Kirkland & Ellis LLP, Aaron Junge, international tax partner at PwC, Arvind Ravichandran, partner at Cravath, Swaine & Moore LLP, and Susan Ryba, partner at McDermott Will & Emery.
Monday, March 3, 2025, 11:45 a.m. – 1:30 p.m. (In Person Only)
Keynote Remarks by Caroline Ciraolo
Kostelanetz partner Caroline Ciraolo will deliver the keynote address during the luncheon program.
Monday, March 3, 2025, 4:00 p.m. to 5:00 p.m. (In Person Only)
When Tax Enforcement Becomes Criminal
Kostelanetz attorney Michael Sardar will co-host a panel on the factors that influence whether IRS criminal investigation agents will seek criminal prosecution. The panel will discuss what IRS-CI agents look for and what the DOJ’s tax division considers when pursuing criminal prosecution, along with the latest trends in criminal tax enforcement.
The panel will be co-run and moderated by Rick Lunger, Division Counsel (Criminal Tax), Office of the Chief Counsel, IRS, U.S. Department of the Treasury.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.
Melissa comes from an actuarial background that grants her a deep understanding of statistics, professional standards, and collaboration with technical, legal, and forensic professionals. Melissa was an assistant general counsel at a Big Four accounting firm with litigation experience in US Tax Court, Court of Federal Claims, and various federal district courts. She focuses her practice on tax controversies, IRS appeals, and representing clients facing government investigation.
Andy focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. He is also a fellow of the American College of Tax Counsel, and a frequent writer and speaker on tax issues.
Will has clerked for the Honorable Mark V. Holmes of the United States Tax Court. He worked on cases concerning the valuations of real property, due process in collections, and complex tax evasion schemes. Will works with clients preparing offers in compromise, requests for audit reconsideration, and other individual representation matters.

Criminal Tax Enforcement at the ABA 40th Annual White Collar Crime Institute
2025-03-04 - 2025-03-07
Kostelanetz partner Caroline Ciraolo will moderate a panel addressing criminal tax matters at the 2025 ABA 40th Annual White Collar Crime Institute, taking place March 5-7, 2025, in Miami, Florida.
The panel is on Wednesday, March 5, 2025, at 10:30 AM and is titled “The Long and Winding Road – From Civil Fraud Referral to Criminal Tax Indictment.” The panelists will review the lifecycle of a criminal tax case that begins as a civil audit or collection matter, travels through the administrative criminal investigation, is referred to the Justice Department (DOJ) Tax Division, and ends with authorization to prosecute. The panelists will discuss what prompts a fraud referral to IRS Criminal Investigation (IRS-CI), how IRS-CI selects its cases, its investigative tools, the applicable standards of review, role of IRS-CI and DOJ Tax conferences, and charging decisions. The panel will also address current criminal tax enforcement priorities, statistics on criminal tax investigations and prosecutions, and cases ripped from the headline.
The ABA White Collar Crime Institute will be held at the Hyatt Regency Miami. There is also an additional Women in White Collar ticketed luncheon and Q&A. You can learn more about the event and register here.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

Gray Proctor Serves as Judge for National Tax Moot Court Competition
2025-03-06 - 2025-03-08
Gray Proctor took up the role of judge for the National Tax Moot Court Competition from March 6-8, 2025 at Stetson University in St. Petersburg, Florida, lending his knowledge and experience to the next generation of tax controversy practitioners.
Gray’s service as a judge is the latest in a long history of service to Floridians. Gray’s tax practice is based out of Kostelanetz’s Atlanta office but he still maintains a separate Florida-centric civil and criminal appellate practice and accepts appointments from federal courts in Florida under the Criminal Justice Act. He is qualified as a board-certified appellate specialist by the Florida Bar Association.
The National Tax Moot Court Competition is hosted by the Tax Section of the Florida Bar. For over 30 years, the event has drawn J.D. and LL.M candidates from around the U.S. to demonstrate their skills in oral arguments and writing briefs. Participants also gain valuable networking opportunities with experienced attorneys to build their tax law careers and gain exposure to variegated tax law practice areas. You can learn more about the competition and stay tuned for 2026 dates here.
About Gray
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal penalties. He also maintains a trial support practice focusing on dispositive motions and other key issues upon which an appeal might follow.

NYU Tax Law Association: Tax Controversy Panel
2025-03-20 13:05 - 14:15 (America/New_York)
Megan Brackney and Eduardo Cukier will participate in a tax controversy panel hosted by the New York University Tax Law Association on March 20, 2025 from 1:05 P.M. to 2:15 P.M.
Megan will moderate the panel, and Eduardo is a speaker. They will join Samantha Rinaldi of Christopher Bryne PLLC; Aaron Esman of Ziering Esman, PLLC; and Fran Obeid of MFO Law PC to discuss the latest developments in tax controversy practice and share their knowledge and experience with NYU Law students.
Megan is an adjunct professor at NYU School of Law, where she teaches courses on tax procedure.
You can learn more about the panel and other NYU Law events here.
About Megan
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. The current Chair-Elect of the American Bar Association Section of Taxation, she is also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.
About Eduardo
Eduardo focuses his practice on international tax issues concerning multinational businesses and high-net-worth clients. Having many years of experience with taxation and legal frameworks in both the U.S. and Latin America, Eduardo works with both domestic and multinational clients from a wide range of industries on foreign and domestic mergers, business restructuring, and cross-border litigation.

Tax Controversy 2025: Navigating the New Enforcement Landscape
2025-03-24
Partner Bryan Skarlatos is co-chairing the Practising Law Institute’s (PLI) one-day program, Tax Controversy 2025: Navigating the New Enforcement Landscape, in New York City on March 24, 2025. Bryan will be joined by Michael J. Desmond of Miller & Chevalier as co-chair, and a myriad of experienced practitioners from other law firms and the IRS will present.
This full-day program will feature several panels that explore the nuances of federal tax controversy issues and how to recognize them before they become tax enforcement risks. Bryan and the other practitioners will walk attendees through the IRS examination process all the way from the initial audit plan through closing conferences, the administrative appeals process, Bipartisan Budget Act of 2015 (BBA) audit procedures, and areas in which the IRS is prioritizing enforcement actions.
Panels discussions in the program include:

Handling an IRS Examination: This panel will explore processes such as the initial audit plan, information document requests, summonses, foreign information requests, third-party contacts, privileges, extensions of the statute of limitations and closing conferences.
Unique Tax Controversy Issues Relating to Partnerships: This panel will focus on steps being taken by the IRS to coordinate partnership audits, discuss partnership-related campaigns and other areas of substantive focus, and provide insight into procedural aspects of the BBA rules, including the determination of imputed underpayments, when the modification rules may be useful, how the modification procedures are being implemented, and pitfalls to watch out for with push-out elections.
IRS Enforcement Priorities: The session will identify areas of IRS enforcement, such as high-income cases, partnership issues, digital assets, Reports of Foreign Bank Accounts (FBAR) violations, employment tax issues, and promoted tax shelters. Panelists will address challenges the IRS will face as it endeavors to implement its strategic operating plan, complicated by issues flowing from tax administration in a global economy, including transfer pricing, competing jurisdictional claims for primary taxing rights, and double taxation and increased application of the Administrative Procedure Act to tax regulations and other guidance.
Recent Tax Cases and Pending Litigation: This panel will review a number of pending and recently decided cases, including Moore, Loper Bright, Corner Post, Varian, 3M, Patel, Liberty Global, and Otay.
Valuation and Valuation Disputes in Tax Cases: This panel will provide an overview of valuation concepts as they arise in tax cases, identify areas of common dispute and controversy, and summarize best practices for securing and defending valuations in tax cases.

After completing this day-long program, participants will be able to:

Anticipate potential federal tax controversy issues before they arise
Assist taxpayers in understanding the compliance and enforcement risks associated with uncertain tax reporting positions and in taking steps to mitigate those risks
Effectively resolve issues in the IRS examination and administrative appeal process

The program is designed for tax attorneys, accountants and in-house tax professionals interested in obtaining a broader understanding of the process for handling tax controversy matters in the context of IRS audits and administrative appeal proceedings and key concepts that arise in tax controversy.
The full-day program will take place at PLI’s New York office on 1177 Avenue of the Americas (entrance on 45th Street). Virtual attendance options are also available. You can learn more about the program and register here.
About Bryan
For more than thirty-five years, Bryan has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice.

Are You a John Doe? The John Doe Summons as a Force Multiplier
2025-03-27
Kostelanetz partner Caroline Ciraolo and associate Abigail Burke will present “Are You a John Doe? The John Doe Summons as a Force Multiplier.” to the Georgetown University Law Center’s Graduate Tax Scholars on March 27, 2025, in Washington, DC. Caroline is an adjunct professor in Georgetown’s Graduate Tax Program, teaching Criminal Tax Law & Procedure and International Tax Controversies. Abigail is an associate in Kostelanetz’s Washington, D.C. office and is a vice-chair of the Women in Tax Law Forum of the Tax Section of the American Bar Association.
The John Doe summons has become a powerful tool for the IRS to find tax evaders and owners of undisclosed offshore accounts when the agency does not know their identities. Combined with global information-sharing agreements like FATCA, the John Doe summons is one of the most formidable tools that the IRS has at its disposal. As federal courts grant the IRS wider usage of John Doe summons to go beyond international tax controversy cases, even including going after gig workers domestically, tax controversy professionals must create procedures for both their clients and their own firms to prepare for John Doe summonses.
You can learn more about the graduate tax program here.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

Tax Relief Tactics: Mastering IRS Penalties, Fines, and Interest Abatement
2025-03-27
Kostelanetz counsel Gray Proctor presents a CLE session for myLaw titled “Tax Relief Tactics: Mastering IRS Penalties, Fines, and Interest Abatement.” Gray’s session, titled “Penalty Defense: Reasonable Cause + A Few More,” is the second half of the two-part CLE series co-sponsored by myLaw and the Federal Bar Association. The first session, titled “Correcting Noncompliance and IRS Penalty Relief,” is presented by Phillip J. Colasanto of Withers Bergman LLP.
In Session II, Gray focuses on reasonable cause and the major role it plays in civil tax controversy and white-collar defense strategies. In many cases, reasonable cause is key to receiving tax penalty mitigation from the IRS. Gray’s session dives into the elements of reasonable cause defenses, including the limits of the defense, the role of disclosure and level of certainty in mitigating penalties, and considerations unique to specific penalties, from failure to file to gross valuation misstatements.
Gray also discusses landmark Supreme Court decisions such as Loper Bright and Jarkesy, which could affect how reasonable cause defenses are utilized going forward.
You can learn more about the webinar and register for the recorded session here.
About Gray
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal penalties. He also maintains a trial support practice focusing on dispositive motions and other key issues upon which an appeal might follow.

Choosing the Ethical Path in Tax Matters: IFA US Branch Conference 2025
2025-03-27 - 2025-03-28
Kostelanetz partner Caroline Ciraolo will speak at the 53rd Annual International Fiscal Association (IFA) U.S. Branch Conference, taking place March 27-28, 2025, in Washington, DC.
The session, titled “Not as Easy as it Looks: Choosing the Ethical Path in Tax Matters,” will be held on March 27, 2025, from 4:15 PM to 5:15 PM. You can learn more about the conference and register here. Early bird registration rates end February 28, 2025.
The International Fiscal Association (IFA) states that it is the leading non-governmental international organization handling international tax matters. With a presence in 111 countries, the U.S. branch is one of the largest IFA branches split into 17 regional chapters dedicated to current international taxation issues, international tax controversy, and connecting international tax professionals from multiple countries.
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.

BBA Partnership Audit Rules – Controversy and Procedure
2025-04-01
Partner Megan Brackney will present on “BBA Partnership Audit Rules – Controversy and Procedure” at the Practising Law Institute’s (PLI) Understanding the BBA Partnership Audit Rules 2025 full-day seminar in PLI’s New York City office on April 1, 2025.
Megan’s panel, which is from 11:45 a.m. to 12:45 p.m., will cover how the Bipartison Budget Act of 2015 (BBA) was enacted to make it easier for the IRS to assess and collect tax attributable to adjustments to partnership-related items. As a result, the law has created new procedural rules for partnership audits. The session will discuss the steps in a BBA audit, the role of appeals, practical challenges for partnership representatives, key deadlines for the IRS, how interest calculations may be larger under the BBA, when penalties may apply and what penalty defenses are available. This session will also discuss judicial review and practical issues arising in BBA audits.
Other participants include Jennifer M. Black, Hans F. Famularo (Invited), Kate Kraus, and Lee S. Meyercord.
Virtual and in-person attendance is offered. You can learn more about the seminar and register here.
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan is the current Chair-Elect of the American Bar Association Section of Taxation and also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.

ABA Annual U.S. and Europe Tax Practice Trends Conference
2025-04-09 - 2025-04-11
Kostelanetz attorneys Caroline Ciraolo, Melissa Wiley, and Heather Fincher will speak on various panels at the ABA Tax Section’s 25th Annual U.S. and Europe Tax Practice Trends Conference, of which Kostelanetz is a proud sponsor.
The U.S. and Europe Tax Practice Trends Conference focuses on international tax compliance, international tax controversy matters, and tax practice trends in the international business sphere. Practitioners, international advisers, and government officials will gain a greater understanding of how the current international business and taxation environments affect multinational corporations.
Caroline, Melissa, and Heather have been asked to speak on international tax controversies, criminal tax matters, current trends in tax enforcement, and more.
The conference will take place at Hotel Okura in Amsterdam on April 9-11, 2025. You can learn more about the conference and register here.
Please join us for the following panels:
Wednesday, April 9, 2025, 4:00 p.m. to 5:30 p.m.
Powerhouse Tax Women in the Know: What’s Top of Mind & Navigating 2025
Kostelanetz attorney Heather Fincher, will co-chair a panel with leading women tax practitioners from multinational businesses. The panel will discuss the most pressing international taxation and regulatory issues of 2025.
Other participants include Natalie Reypens of Loyens & Loeff, a fellow co-chair of the panel; Luana Foffo Ciucci, Director, Southern & South East Europe, Procter & Gamble, Rome; Federica Pitrone, Head of International Tax, Intesa Sanpaolo SpA, Milan; Sonja Schiller, Counsel, Alphabet Regulatory Response, Investigations & Strategy, Seattle, WA; and Jenny Wong, Vice President, North American Tax Insurance, Ryan Transactional Risk, New York, NY.
Thursday, April 10, 2025, 4:30 p.m. to 6:00 p.m.
Criminal Tax
Kostelanetz attorney Caroline Ciraolo will co-chair a panel on criminal tax matters and international tax matters.
Other participants include fellow co-chair Sabine Stetter of Stetter Attorneys at Law, Munich; Jeffrey Neiman of Marcus Neiman Rashbaum & Pineiro LLP, Fort Lauderdale, FL; Silvia Martina of Cagnola & Associati Studio Legale, Milan; and Alice Rousseau of Alice Rousseau Avocats, Paris.
Friday, April 11, 2025, 12:15 p.m. to 1:30 p.m.
What to Do With All the Data? Substantiating Tax Positions in the Face of Tidal Waves of Data
Kostelanetz attorney Melissa Wiley will speak on a panel that delves into how Big Data has changed tax investigations and how to best advocate for your client in light of the large amounts of data available to taxing authorities worldwide.
Other participants include co-chair Thomas Linder of MME Legal, Zurich; co-chair Travis Thompson of Boutin Jones, San Francisco, CA; Ramona Azzopardi of WH Partners, Ta’ Xbiex; Alexandra Courela of Abreu Advogados, Lisbon; Stefan Richter of YPOG, Hamburg; and Wouter Vosse of Hamelink & Van den Tooren N.V., Amsterdam.
About Kostelanetz’s Speakers
Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
Melissa comes from an actuarial background that provides her a deep understanding of data analysis, statistics, and collaboration with technical, legal, and forensic professionals. Melissa was an assistant general counsel at a Big Four accounting firm and has litigation experience in the U.S. Tax Court, Court of Federal Claims, and various federal district courts. She focuses her practice on federal and state tax controversies international information reporting compliance, and representing clients facing government investigation.
Heather focuses her practice on multinational businesses and high net-worth individuals in need of international tax planning. She counsels both U.S.- and foreign-owned businesses and individuals regarding the U.S. tax consequences of cross-border investments, cryptocurrency issues, mergers and acquisitions, joint ventures and restructurings. Heather also regularly advises clients on special issues arising in international tax controversies. Heather is also the co-founder of the ABA’s Women in Tax Forum.

Domestic & Foreign Partnership Tax Planning Seminars at PLI Institute
2025-04-22 - 2025-04-24
Partner Megan Brackney and counsel Andy Weiner will present two seminars at the Practicing Law Institute’s (PLI) Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2025 program in Chicago, IL on April 22-24, 2025.
PLI’s 3-day program is dedicated to the intricacies of Subchapter K and partnership taxation. The third day is expressly designated for highly complex partnership and joint venture issues, tax planning, audit defense, and industry-specific topics in partnership taxation.
You can learn more about the PLI partnership tax planning program and register here.
Kostelanetz attorneys will share their experience and knowledge in the following seminars:
BBA Partnership Audit Rules in the Transactional Context
April 24, 2025, 8:30 AM CDT
Megan Brackney will participate in this session which focuses on the transactional contexts of BBA (Bipartisan Budget Act of 2015) audit rules when a partnership liquidates and whether the cease-to-exist rules or failure-to-pay rules apply, and how to advise clients on the risks and benefits of BBA indemnities.
Other panelists include Jennifer M. Black and Kate Kraus.
Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Partnership Tax Advisor Should Know
April 24, 2025, 4:15 PM CDT
Andy Weiner will participate in this panel which focuses on the ethical standards of advising clients in partnership and other pass-through entity transactions as provided in the Internal Revenue Code, Circular 230, AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct. The panel will highlight ethical pitfalls as well as privileges and rights of the taxpayer.
Other panelists include Bradley M. Seltzer.
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan is the current Chair-Elect of the American Bar Association Section of Taxation, and a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and tax controversy.
Andy focuses on tax controversies, both civil and criminal, at the agency level and in litigation. He has argued more than 50 tax cases in the U.S. courts of appeals. Andy is a fellow of the American College of Tax Counsel, a contributor to Forbes on tax controversy and tax policy issues, and a frequent writer and speaker on tax issues.

Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know
2025-04-24
Andy Weiner will present on a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” at the Practicing Law Institute’s (PLI) three-day Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances conference in Chicago on April 24, 2025.
Andy’s panel, co-run with Bradley Seltzer of Holland & Knight, will focus on practice standards and ethical standards that apply to practitioners during the partnership tax planning process. Attendees will learn the key provisions related to advising clients on partnership and pass-through transactions under Circular 230, AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct and how to navigate the ethical pitfalls that may arise when providing tax opinions and recommending return positions.
PLI’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances conference is a comprehensive three-day program designed for tax law and complex commercial litigation professionals of all skill levels. The first two days of the event are dedicated to the framework and intricacies of Subchapter K, with the third day devoted to specialized topics like ethics rules, specific industries, and international tax compliance tailored to practitioners focusing on partnership taxation. The conference will take place April 22-24, 2025, at 300 East Randolph Street, Suite 5000, near Millennium Park. Virtual attendance options are also available. You can learn more about the conference and register here.
About Andy
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has argued approximately 50 tax cases in the U.S. courts of appeals. He is a Forbes contributing columnist on tax controversy and tax policy and a frequent writer and speaker on tax issues. He is also a fellow of the American College of Tax Counsel.
