Kostelanetz LLP

Daniel Cady Davidson Participates In And Zenia Memon Moderates A Webinar Entitled "Careers in Tax Law" For The Federal Bar Association's Younger Lawyers Division And Section On Taxation
2022-08-05 14:00 - 15:00 (America/New_York)
Description: On August 5, 2022, Daniel Cady Davidson participates in and Zenia Memon moderates a webinar entitled “Careers in Tax Law” for the Federal Bar Association’s Younger Lawyers Division and Section on Taxation. Members of the Federal Bar Association, young tax practitioners, and aspiring students are invited to listen to a panel of tax practitioners speak about the nature of their jobs, their experience in different areas of tax law, and what young tax professionals and aspiring students might expect from a career in tax law.
Moderators:

Ege Berber, PwC
Zenia Memon, Kostelanetz & Fink LLP

Panelists:

Daniel Cady Davidson, Kostelanetz & Fink LLP
Teisha Ruggiero, Internal Revenue Service
Nick Zemil, PwC

Click here to register.

Don Fort Moderates A Panel Entitled "Illuminating the Shadow Economy: Using Publicly Available Data to Gain Visibility into Financial Crime" For ACFCS's Fincrime Virtual Week 2022
2022-08-04 09:00 - 10:00 (America/New_York)
On August 4, 2022, Don Fort moderates a panel entitled “Illuminating the Shadow Economy: Using Publicly Available Data to Gain Visibility into Financial Crime” for the Association of Certified Financial Crime Specialists’ Fincrime Virtual Week 2022.
Description: The evolving shadow economy – from short-term rentals to crypto and NFTs – poses significant challenges to regulators and investigators. However, practitioners can use publicly available data to gain actionable visibility into illicit business activity and potential financial crime. In this session, experts offer multiple perspectives from government and financial services on how to leverage publicly available data and open-source intelligence to combat financial crime and throw light on the shadows.
Moderator:

Don Fort, Director of Investigations, Kostelanetz and Fink, LLP

Panelists:

Jarod Koopman, Acting Executive Director, IRS Criminal Investigation / Cyber and Forensics Division
Matan Fattal, Co-Founder and CEO, IVIX
Teya Dyan, Fraud & Security Solutions, SAS

Click here for more information and to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!" At The 29th Annual Estate And Gift Tax Conference
2022-07-29 15:30 - 17:00 (America/New_York)
On July 29, 2022, Caroline D. Ciraolo participates in a panel entitled “Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!” at the 29th Annual Estate and Gift Tax Conference. MCLE credit is offered for this event.
Description:
We live in a global economy and many clients have sources of income, investments, assets, or activities outside the United States. For U.S. persons, this means having to comply with a complex web of reporting obligations under the Internal Revenue Code and the Bank Secrecy Act. This panel addresses the rules of the road with respect to foreign trusts and the receipt of gifts from foreign individuals and entities. The panelists address the reporting requirements, consequences of noncompliance, paths to compliance, recent enforcement actions and litigation, and best practices in challenging the often substantial penalties.
Speakers:
Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Kurt Kawafuchi, Lecturer of Accounting, University of Hawaiʻi at Mānoa Shidler College of Business
Marsha Dungog, Partner, Withersworldwide
Click here for more information and to register.

Michael Sardar Teaches A Course Entitled “A Primer On International Information Returns: Basic Filing Obligations, Penalties, And Pathways To Compliance For The Non-Compliant Taxpayer” For New York University's Advanced Subchapter S Tax Conference
2022-07-22 15:15 - 16:30 (America/New_York)
On July 22, 2022, Michael Sardar teaches a course entitled, “A Primer On International Information Returns: Basic Filing Obligations, Penalties, And Pathways To Compliance For The Non-Compliant Taxpayer” for New York University’s Advanced Subchapter S Tax Conference.
Course Description:
The Advance Subchapter S Conference provides sophisticated knowledge of the “hot button” issues and intricacies of Subchapter S such as:

Distribution and redemption rules applicable to S corporations
Subchapter S eligibility and election requirements
Section 199A and its application to S corporations
Using trusts and S corporations shareholders
State income taxation of S corporations
Tax planning in light of new and recent tax developments

Presenter:

Michael Sardar, Partner, Kostelanetz & Fink LLP

Click here to register and for more information.

Caroline D. Ciraolo Moderates A Panel Entitled "Diversity in the Tax Bar" For The Law Firm Anti-Racism Alliance's Tax System Working Group Discussion Series
2022-07-20 14:00 - 15:30 (America/New_York)
Description: On July 20, 2022, Caroline D. Ciraolo moderates a panel entitled “Diversity in the Tax Bar” for the Law Firm Anti-Racism Alliance’s Tax System Working Group Discussion Series. The discussion series, which is operated in conjunction with the American College of Tax Counsel, the American Tax Policy Institute and the Tax Section of the American Bar Association, details the current state of diversity in the tax bar, opportunities for diverse tax attorneys in different practice settings, and steps that the tax bar should be taking to create sustainable diversity, equity and inclusion strategies. This panel discussion addresses recruiting and retaining diverse tax lawyers from the tax controversy practice.
Moderator:

Caroline D. Ciraolo, Kostelanetz & Fink LLP

Panelists:

Antoinette L. Ellison, Jones Day
Jenny L. Johnson, McDermott Will & Emery
Kelley C. Miller, Reed Smith LLP

Click here to register.

Ian Weinstock Teaches A Course Entitled “FBARs and Entities – Who Must File?” For The CPA Academy
2022-07-07 10:00 - 11:00 (America/New_York)
On July 7, 2022, Ian Weinstock teaches a course entitled, “FBARs and Entities – Who Must File?” for the CPA Academy.
Course Description:
While it is generally clear-cut whether or not an individually owned foreign account needs to be reported on an FBAR, it is less obvious when a foreign account owned by an entity needs to be reported—either by the entity itself or by some individual associated with the entity. This course is intended to provide guidance on FBAR filing obligations in these less-obvious contexts.
Learning Objectives:

Identify who needs to report
Summarize the FBAR filing obligations
Describe the less-obvious situations and who files

Presenter:

Ian Weinstock, Partner, Kostelanetz & Fink LLP

Caroline D. Ciraolo Participates In A Panel Entitled "IRS Compliance for Offshore Trusts and Gifts" At The 2022 Annual Meeting And Education Conference For The American Academy Of Attorney-CPAs
2022-06-25 10:00 - 11:15 (America/New_York)
On June 25, 2022, Caroline D. Ciraolo participates in a panel entitled “IRS Compliance for Offshore Trusts and Gifts” at the 2022 Annual Meeting and Education Conference for the American Academy Of Attorney-CPAs .
Description:
In January 2017, the IRS Large Business & International Division (“LB&I”) announced the first 13 compliance campaigns – issue-based examinations and deployments of resources to areas that present a level of risk or need for education. On May 21, 2018, LB&I announced the approval of the Form 3520/3520-A compliance and campus-assessed penalties campaign. This campaign was focused on the information returns associated with foreign trusts and foreign gifts and designed to “take a multifaceted approach to improving compliance with respect to the timely and accurate filing of information returns reporting ownership of and transactions with foreign trusts.” This panel reviews the foreign trust and foreign gift reporting obligations, the potential penalties and defenses, recent enforcement actions, and what lies ahead for taxpayers seeking to come into compliance.
Panelists:
Richard Chisholm, JD, WardChisholm LLP
Caroline D. Ciraolo, LLM, JD, Kostelanetz & Fink, LLP
Dan Rosefelt, Esq., CPA, Rosefelt Tax Law
Click here for more information and to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Coming in From the Cold: The Future of Voluntary Disclosures" At The 14th Annual NYU Tax Controversy Forum
2022-06-24 14:45 - 15:45 (America/New_York)
On June 24, 2022, Caroline D. Ciraolo participates in a panel entitled “Coming in From the Cold: The Future of Voluntary Disclosures” at the 14th Annual NYU Tax Controversy Forum.
Description:
For more than 70 years, the IRS has maintained a voluntary disclosure policy designed to encourage taxpayers to come in from the cold and self-report noncompliance. In 2018, the voluntary disclosure program was updated to provide new procedures. In its most recent annual report, the Taxpayer Advocate Service noted that the new procedures are substantially more onerous and uncertain than the old procedures, and may actually discourage taxpayers from stepping forward to self-disclose. This panel discusses the latest voluntary disclosure developments, including the application of the updated program to cryptocurrency, and provides suggestions on how practitioners should advise their clients to make the best use of the new voluntary disclosure procedures.
Moderator:
Phillip Colasanto, Esq., Associate, Agostino & Associates, PC, Hackensack, NJ
Panelists:
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
Mark Matthews, Esq., Member, Caplin & Drysdale, Washington, DC
Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
Click here for more information and to register.

14th Annual NYU Tax Controversy Forum To Be Held June 23 and 24, 2022!
2022-06-23 - 2022-06-24
Kostelanetz & Fink is pleased to sponsor the 2022 NYU Tax Controversy Forum, which will be held on Thursday and Friday, June 23 and 24, 2022, at the Westin New York Grand Central. We will be live and in-person again this year, with the option of livestreaming for remote attendees.
For more than a decade, the NYU School of Professional Studies Tax Controversy Forum has been bringing together representatives from the government and expert private practitioners to compare perspectives on a variety of topics involving federal tax audits, appeals, and litigation. The forum covers a wide range of controversy work, from procedural seminars to substantive programs, international issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties. And next year’s forum will feature the same powerful and thought-provoking content that is so critical to those who attend each year.
For Forum agenda and registration link, click here. For updates on the Forum and other important tax-related legal news, please sign up for our newsletter here.

Caroline D. Ciraolo Co-Chairs A Panel Entitled "Criminal Tax Update" At The 14th Annual U.S. and Latin America Tax Practice Trends Conference
2022-06-16 13:30 - 15:00 (America/New_York)
On June 16, 2022, Caroline D. Ciraolo co-chairs a panel entitled “Criminal Tax Update” at the 14th Annual U.S. and Latin America Tax Practice Trends Conference, hosted by the ABA Section of Taxation, the International Bar Association (Taxes Committee), and the International Fiscal Association – USA Branch.
Conference Description:
Returning to the Mandarin Oriental Miami after a two-year hiatus, the 14th Annual U.S. and Latin America Tax Practice Trends Conference focuses on practical tax practice trends for multinational corporations and their international advisors and provides insight into how government tax officials may view the international tax landscape in light of important international developments that impact corporate taxpayers. Panelists include industry leaders, senior government and OECD officials, and leading tax practitioners from the United States and Latin America.
Click here for more information and to register.

Sharon L. McCarthy Participates In A Panel Entitled "When Failure to File a Return Becomes Criminal" At The 2022 IRS Representation Conference
2022-06-10 15:30 - 16:30 (America/New_York)
On June 10, 2022, Sharon L. McCarthy participates in a panel entitled “When Failure to File a Return Becomes Criminal” at the 2022 IRS Representation Conference.
Description:
This panel reviews the fundamentals of representing taxpayers in civil tax controversy by focusing on representing taxpayers who have failed to file tax returns. The program provides an overview of the key statutes and procedures, including potential penalties, and available defenses. The discussion reviews what causes the failure to file a return or several returns to move from a civil issue to a criminal issue, and what federal prosecutors look for when determining to pursue the issue as a criminal violation.
Moderator:
Barbara Kaplan, Esq. Greenberg Traurig, LLP, New York, NY
Panelists:
Sharon McCarthy, Esq., Kostelanetz Fink LLP, New York, NY
Anastasia King, Assistant United States Tax Attorney, Department of Justice, New Haven, CT
Maria Papageorgiou, Special Agent, IRS Criminal Investigation, Bridgeport, CT
Click here for more information.

Sharon L. McCarthy Participates In A Panel Entitled "The Criminal Tax Case From Start to Finish" At The 2022 IRS Representation Conference
2022-06-10 09:30 - 10:30 (America/New_York)
On June 10, 2022, Sharon L. McCarthy participates in a panel entitled “The Criminal Tax Case From Start to Finish” at the 2022 IRS Representation Conference.
Description:
This panel reviews how criminal tax cases get started, how cases are worked, and what the process is from start to finish. The panel focuses on the role of the Kovel accountant and when the Kovel arrangement works and does not work.
Moderator:
Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Panelists:
Sharon McCarthy, Esq., Kostelanetz Fink LLP, New York, NY
Maria Papageorgiou, Special Agent, IRS Criminal Investigation, Bridgeport, CT
Kristen Rico, Esq., Senior Counsel, IRS Office of Chief Counsel, Internal Revenue Service, Philadelphia, PA
Click here for more information.

Megan L. Brackney Leads A Program Entitled “Ethical Dilemmas in Representation” For ENGAGE 22
2022-06-08 15:30 - 16:45 (America/Los_Angeles)
On June 8, 2022, Megan L. Brackney leads a program entitled “Ethical Dilemmas in Representation” for ENGAGE 22, a conference hosted by the American Institute of Certified Public Accountants (AICPA) and the Chartered Institute of Management Accountants (CIMA) in Las Vegas, Nevada.
Description: This program covers the Circular 230 and AICPA ethics rules that apply to tax practitioners, and how they can help attorneys navigate difficult situations with clients. Brackney discusses the ethical duties when discovering a client’s non-compliance, how to handle a client who does not want to cooperate with an audit, and how to correct false information provided by the client to the IRS. CPE credit is offered for this event.
Learning Objectives:

Recall the ethical rules that apply to practitioners who represent clients before the IRS.
Identify strategies for handling difficult situations with clients who are not compliant.

Speaker

Megan L. Brackney, Partner, Kostelanetz & Fink, LLP;

Click here for more information and to register.

Bryan C. Skarlatos Participates In A Panel Discussion Entitled “Corporate Transparency Act: Reporting of Real Estate Transactions and other Bank Secrecy Act Amendments Affecting Tax Practitioners"
2022-06-08 12:00 - 13:00 (America/Los_Angeles)
On June 8, 2022, Bryan C. Skarlatos participates in a panel discussion entitled “Corporate Transparency Act: Reporting of Real Estate Transactions and other Bank Secrecy Act Amendments Affecting Tax Practitioners” hosted by The Florida Bar Association.
Description: This program will cover the following topics:

Overview of selected portions of the AML Act of 2020.
Changes to cryptocurrency rules.
Regulation of antiquities and possibly artwork.
Criminal law statutory additions and penalty changes.
Corporate Transparency Act.
2022 Regulatory Initiatives.

Panelists

Ian Comisky, icomisky@foxrothschild.com
Lester M. Joseph, lester.m.joseph@wellsfargo.com
Bryan C. Skarlatos, bskarlatos@kflaw.com

Click here for more information and to register.

Megan L. Brackney Participates In A Panel Entitled “Ethics in 2022: Privilege on Trial, Practice on the Move” For The 50th Annual Conference Of The USA Branch Of The International Fiscal Association
2022-06-03 15:45 - 16:45 (America/New_York)
On June 3, 2022, Megan L. Brackney participates in a panel entitled, “Ethics in 2022: Privilege on Trial, Practice on the Move” for the 50th Annual Conference of the USA Branch of the International Fiscal Association.
Event Description: The 50th Annual Conference of the USA Branch of the International Fiscal Association includes two full days, Thursday, June 2 and Friday, June 3, of substantive sessions on international tax topics, featuring prominent speakers from private practice, industry, and government. At the conclusion of this program, participants will be able to:

Discuss the technical aspects of recent changes in US tax rules in various specialty areas. Examples are BEAT, the FTC and GILTI.
Discuss what is coming from the OECD, Congress, and other countries. Focus will be on Pillars I and II.
Engage in effective tax planning for client and employers, especially re. cryptocurrency, dispute resolution, IRS guidance, and reliance on tax treaties.

Panel Description: The “Ethics in 2022: Privilege on Trial, Practice on the Move” panel will discuss two core ethics issues that demand a fresh look in 2022: the availability of attorney-client privilege protection and the significance of practice limitations. The 9th Circuit rejected assertions of privilege by an international tax law firm regarding attorney-client communications involving legal and nonlegal advice. What could the court’s ruling, which is now on appeal to the Supreme Court, mean for attorney-client relations? Are other protections available? How can lawyers best protect their clients going forward – and what additional concerns arise cross-border? Also new in 2022 is the permanency of long-term hybrid and remote work. What initially emerged as a temporary pandemic response has become a workplace commitment in many firms. Now these firms need to take a careful look at practice of law limitations, in the US and beyond.
Moderator:

Diane Ring, Boston College

Panelists

Megan L. Brackney, Esq., Kostelanetz & Fink, LLP;
Amanda Leon, Caplin & Drysdale

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

Caroline D. Ciraolo Participates In A Panel Entitled "Aggressive Tax Enforcements: You Can Run but Cannot Hide…" For The Cambridge Forums Forum on International Tax & Disputes
2022-05-27
On May 27, 2022, Caroline D. Ciraolo and Stephanie Kamp LL.M., stetter Rechtsanwaite, Munich, Germany, moderate a group discussion titled, “Aggressive Tax Enforcements: You Can Run but Cannot Hide…” at the International Tax & Disputes Forum, hosted by Cambridge Forums in Surrey, United Kingdom.
Description:
In the face of substantial and rising Tax Gaps, limited resources, and complex and sophisticated abusive transactions, tax authorities around the world are looking to leverage available tools and relationships to identify potential tax offenders, investigate the conduct, and hold those violating the tax laws accountable. These efforts include the use of bilateral and multilateral treaties and agreements to obtain information and documents across borders. The Joint Chiefs of Global Tax Enforcement, established in 2018 by the United States, the United Kingdom, Canada, the Netherlands, and Australia, is just one example of the collaboration among treaty partners that is leading to the increase in domestic and international criminal tax investigations. Taxpayers and their advisors need to be aware of developments on the world stage and understand the implications for criminal tax enforcement. Attendees will discuss global tax enforcement priorities, investigative tools, cross-border investigations, and resource allocations.
Forum on International Tax & Disputes
The Steering Committee welcomes up to 40 senior tax directors and leading lawyers personally selected from renowned regional and national firms and corporations around the world. With increased transparency and information sharing amongst tax authorities, as well as the use of aggressive techniques like criminal investigations and digital taxation on the rise, the Forum provides an opportunity to keep abreast of developments in key jurisdictions around the world.
Using candid, seminar-style discussion, the group shares experiences and engages in meaningful dialogue on the most pressing issues they face.
Forum Co-Chairs:
• Michael J. Miller, Roberts & Holland LLP, United States
• Joseph Duffy, Matheson, Ireland

Christopher M. Ferguson Teaches A Course Entitled “Walking on Eggshells: How to Handle An Eggshell Audit” For The CPA Academy
2022-05-24 18:00 - 19:00 (America/New_York)
On May 24, 2022, Christopher M. Ferguson teaches a course entitled, “Walking on Eggshells: How to Handle An Eggshell Audit” for the CPA Academy. CLE and CPE credit is offered for this event.
Course Description: An IRS audit can be a harrowing experience under any circumstances. When there is the risk of a criminal referral, otherwise known as an “eggshell audit,” the stakes increase drastically. This presentation covers many of the unique aspects of eggshell audits, including; (i) how to handle Information Document Requests and dealings with the civil exam agent; (ii) how to recognize badges of fraud; (iii) how and when to assert a client’s Fifth Amendment rights; (iv) how to handle ongoing tax compliance in the midst of an eggshell audit; (v) how to conduct a “shadow audit” while preserving privilege; and (vi) how to recognize that a criminal referral is being contemplated or has been made. The presentation also includes practice tips for navigating an eggshell audit ethically while trying to prevent the eggs from breaking.
Presenter:

Christopher M. Ferguson, Partner, Kostelanetz & Fink LLP

Megan L. Brackney Participates In A Panel Entitled “Coming in from the Cold: Dealing with Non-Filers” For The TRN's Forensic Accounting Summit
2022-05-20 08:40 - 10:00 (America/New_York)
On May 20, 2022, Megan L. Brackney participates in a panel entitled, “Coming in from the Cold: Dealing with Non-Filers” for the Forensic Accounting Summit, an all-day program hosted by the Tax Rep Network.
Event Description: Taxes are at the heart of our economic engine. Though we have a “voluntary tax system,” it’s not THAT voluntary! The IRS makes a point of pursuing taxpayers who fail to uphold their end of the bargain and is currently pursuing the more than 10 million non-filers, many of whom are high-income earning. This full-day conference will bring experts from around the country together to review how the process works to bring in non-filers, handle the IRS, and what to watch out for to protect yourself from ethical pitfalls. It will also review reconstruction techniques that come up far too often in bankruptcies, divorce, and civil and criminal tax matters, with an emphasis on how to present the information to the IRS. Finally, we will review how to lay the groundwork early to avoid or abate penalties when these issues arise.
Panel Description: The IRS is pursuing more than 10 million non-filers that they have already identified, plus countless others that get swept up in ongoing audits and investigations. For those taxpayers not yet contacted, interesting decisions await: to simply file or submit a request to be pre-cleared into voluntary disclosure? And which one is best for what situation? Our panel of professionals will review the current state of voluntary disclosure, how to determine which option is best for the client, and how to bring them in without triggering a criminal referral.
Moderator:

Eric L. Green, Esq., Green & Sklarz LLC

Panelists

Megan L. Brackney, Esq., Kostelanetz & Fink, LLP;
Laura L. Gavioli, Esq., Alston Bird

Click here for more information and to register.

Caroline D. Ciraolo Participates In A Panel Entitled "State, Local, and International Collection of Tax" For The 7th International Conference On Taxpayer Rights
2022-05-19 10:00 - 11:30 (America/New_York)
On May 19, 2022, Caroline D. Ciraolo participates in a panel entitled “State, Local, and International Collection of Tax” at the 7th International Conference on Taxpayer Rights: Tax Collection & Taxpayer Rights in the Post-COVID World, hosted by the Center for Taxpayer Rights.
Description:
This panel examines the European and US experience with conflicts of law and procedures between different states and localities with respect to the collection of tax. Information-sharing and the authority and ability of countries to reach assets in another country are discussed, as well as the availability of inter-governmental dispute resolution in the collection arena.
Moderator:

Joshua Odintz, Holland & Knight, United States

Panelists:

Caroline D. Ciraolo, Kostelanetz & Fink, LLP, United States
Katerina Perrou, Post-Doctoral Researcher and Lecturer in Tax Law, National and Kapodistrian University of Athens; Legal Counsel to the Governor of the IAPR, Greece
Luk Vandenberghe, Head of Sector Tax Enforcement and Mutual Assistance, European Commission, Taxation & Customs Union Directorate General, Belgium

Click here for more information and to register.

Don Fort Participates In A Panel Entitled "The US Treasury's National Illicit Finance Strategy: A Closer Look" with AML RightSource
2022-05-18 15:00 (America/New_York)
On May 18, 2022, Don Fort participates in a panel entitled “The US Treasury’s National Illicit Finance Strategy: A Closer Look” with AML RightSource.
Description: Members of the AML RightSource Advisory Board will provide their insight on the U.S. Department of the Treasury’s 2022 National Illicit Finance Strategy, a comprehensive and potentially far-reaching document that among other things highlights:

The illicit finance risk posed by the abuse of legal entities;
The complicity of professionals that misuse their positions or businesses;
Small-sum funding of domestic violent extremism networks;
The effective use of front and shell companies in proliferation finance;
The exploitation of the digital economy

Panelists:

Don Fort, Director of Investigations, Kostelanetz and Fink, LLP
Rick Small, Executive Vice President and Director, Financial Crimes Program, BB&T
Teresa (Terry) Pesce, President and CEO, Terry Pesce & Co LLC
John Byrne, Executive Vice President and Chairman, AML RightSource

Click here for more information.

Megan L. Brackney Presents In A Webinar Entitled “Ethical Dilemmas - The IRS's Enforcement of Foreign Information Return Penalties and the Practitioner's Duty to Promote Compliance” For The International Tax Institute
2022-05-17 13:00 - 14:00 (America/New_York)
On May 17, 2022, Megan L. Brackney presents in a webinar entitled, “Ethical Dilemmas – The IRS’s Enforcement of Foreign Information Return Penalties and the Practitioner’s Duty to Promote Compliance” for the International Tax Institute.
Presenters

Megan L. Brackney, Kostelanetz & Fink, LLP;
William E. (“Buck”) Buchanan, Grant Thornton; and
Katrina Robinson, Teton Trust Company

The International Tax Institute offers 1 hour of New York CLE and New York CPE credit for this webinar. Instructions for qualifying for CLE and CPE credit will be provided during registration and at the start of the webinar.
Click here for more information and to register.

Don Fort Participates In Keynote Fireside Chat At ACAMS Law Enforcement Anti-Financial Crime Seminar
2022-05-16 09:10 - 10:00 (America/New_York)
On May 16, 2022, Don Fort participates in a keynote fireside chat at the two-day virtual Law Enforcement Anti-Financial Crime Seminar of ACAMS, the largest international membership organization for Anti-Financial Crime professionals. Moderating the fireside chat is Jim Lee, Chief of the Internal Revenue Service-Criminal Investigation (IRS-CI).
Description: Law enforcement is on the front lines of fighting financial crime — and those lines are shifting amid emerging threats and increasingly sophisticated criminals. ACAMS first Law Enforcement Anti-Financial Crime Seminar brings information-rich sessions, led by seasoned investigators from the public and private sectors. From cybercrime to cryptocurrencies, public-private partnerships to preparing cases for trial, attendees gain expertise for immediate professional benefit and invaluable insights for mastering this fast-changing environment.
Featured Sessions:
– Best Practices in Organizing and Executing Financial Crime Investigations
– Understanding the Inner Workings of Financial Institutions’ Anti Financial Crime Programs As An Asset to Your Investigations
– Enhancing Your Subpoena Process for More Effective Financial Crime Investigations
– Forging Public-Private and Inter-Agency Alliances to Foster Information Sharing and Strengthen Investigations
– Addressing Criminal Typologies of FinTech, Crypto and Other Payment Processors
– Building an Effective Financial Fraud and Money Laundering Case for Trial
– Using Seizure Warrants to Support Financial Crime Investigation
Click here for more information and to register.

Jay Nanavati Participates In A Panel Entitled "Search Warrants, Subpoenas and Summonses: Recent Taxpayer Challenges and Legal Developments" For The ABA’s Hybrid 2022 May Tax Meeting
2022-05-14 09:40 (America/New_York)
On May 14, 2022, Jay Nanavati participates in a panel entitled, “Search Warrants, Subpoenas and Summonses: Recent Taxpayer Challenges and Legal Developments” for “Hybrid 2022 May Tax Meeting” hosted by the American Bar Association’s Section of Taxation.
Description: During criminal tax investigations, the Government has many evidence-gathering tools and processes at its disposal, including search warrants, subpoenas and summonses. In civil tax cases, the Government frequently
uses summonses to gather information and documents. This panel will discuss the Government’s use of these
tools, recent taxpayer challenges, including those involving the use of filter teams, and legal developments in this
area. The panel will also discuss best practices for representing your clients and protecting privileges when you
learn of a search warrant, or service of a summons or subpoena. CLE credit is offered for this event.
Moderator:

Sara Neill, Shareholder, Capes Sokol

Panelists:

Caryn Finley, Assistant United States Attorney, Western District of North Carolina;
Jay Nanavati, Kostelanetz & Fink, LLP; and
S. Starling Marshall, Crowell & Moring, LLP

This event is available to attend in-person or remotely.
Click here for more information and to register.

Megan L. Brackney Participates In A Panel Entitled “Moral and Ethical Duties Around Diversity, Equity, and Inclusion” For The ABA's Hybrid 2022 May Tax Meeting
2022-05-13 15:10 (America/New_York)
On May 13, 2022, Megan L. Brackney participates in a panel entitled, “Moral and Ethical Duties Around Diversity, Equity, and Inclusion” for “Hybrid 2022 May Tax Meeting” hosted by the American Bar Association’s Section of Taxation.
Description: Fostering a workplace environment for different voices, perspectives, and backgrounds provides a space where employees feel welcome to express their ideas and be heard. However, without inclusive leadership and recognition of bias, organizations may miss an opportunity to hear new ideas or even the concerns of their employees. This panel will engage in a discussion about the intersection of ethics and diversity, equity, and inclusion (DE&I). In evaluating the ethical duties in tax practice, panelists will identify where tax practitioners have a professional responsibility to promote diversity, equity, and inclusion in their practice. Panelists will also discuss the moral case for DE&I in tax practice – what should we be doing as tax professionals.
Learning Objectives:
After attending the session, the participant will be able to:

Identify professional responsibility rules for tax practitioners and how these rules relate to diversity, equity, and inclusion efforts;
Discuss what tax practitioners can do to make impactful changes in achieving a diverse and inclusive profession; and
Identify how implicit bias within office management may impact diverse attorneys.

Moderator:

Catherine Sullivan, IRS Office of Chief Counsel

Panelists

Megan L. Brackney, Kostelanetz & Fink, LLP;
David Farhat, Skadden, Arps, Slate, Meagher & Flom, LLP; and
Additional Panelists TBA

This event is available to attend in-person or remotely.
Click here for more information and to register.

Jay Nanavati Participates In A Panel Entitled "Targeting Tyrants, Toadies, Tax Evaders, Oligarchs, and the Ostensible Gatekeepers" For The ABA’s Hybrid 2022 May Tax Meeting
2022-05-13 09:15 (America/New_York)
On May 13, 2022, Jay Nanavati participates in a panel entitled, “Targeting Tyrants, Toadies, Tax Evaders, Oligarchs, and the Ostensible Gatekeepers” for “Hybrid 2022 May Tax Meeting” hosted by the American Bar Association’s Section of Taxation.
Description: Navigating the new tax & transparency policies aimed at unmasking “beneficial owners” and stopping the shell games. For decades, offshore financial centers have competed fiercely with each other to attract wealthy individuals and families by offering them not only low tax rates, but also a private place to protect their assets from creditors and regulators. Circuitous investment strategies — involving tiers of shell companies, private banks, and Wall Street connections — have facilitated the “legal” placement of billions of dollars with prominent US hedge funds and PE firms. Despite KYC compliance, the true beneficial owners often remain anonymous, allowing every “gatekeeper” (i.e., attorneys, accountants, and investment advisors) plausible deniability — i.e., the ability to honesty say that he or she was not knowingly working directly for an illicit enterprise. In December 2021, FinCEN issued proposed regulations implementing the 2020 Corporate Transparency Act, the purpose of which is to create a national “beneficial ownership registry,” and to combat, to the broadest extent possible, the proliferation of anonymous shell companies that facilitate the flow and sheltering of illicit money in the United States. Meanwhile, Russia’s invasion of Ukraine has had this unexpected side effect: demonstrating that the complex offshore financial system can dismantle itself. In March 2021, the IRS asked Congress for more resources in implementing the Biden Administration’s sanctions program, along with DOJ’s “kleptocracy task force.” Senator Wyden has introduced a bill to eliminate certain tax and treaty benefits for Russian oligarchs. On a multilateral level, the US Treasury has joined other countries to launch the “Russian Elites, Proxies, and Oligarchs (REPO) multilateral task force. Panelists will discuss these new tax policy and transparency initiatives, and their implications for practitioners, including new due diligence concerns, the attorney-client privilege, the duty of confidentiality, and compliance issues in identifying the true “beneficial owners” of complex structures, and reporting to FinCEN the names of the professionals who helped create them.
Moderator:

Pamela A. Fuller, Tully Rinckey, Zahn Law

Panelists:

Alan Granwell, Holland & Knight, LLP
Bruce Zagaris, Berliner, Corcoran & Rowe, LLP
Jay Nanavati, Kostelanetz & Fink, LLP
Marco Rossi, Marco Q. Rossi & Associati, PLLC

This event is available to attend in-person or remotely.
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Bryan C. Skarlatos Participates In A PLI Panel Entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know”
2022-05-11 16:00 - 17:30 (America/New_York)
On May 11, 2022, Bryan C. Skarlatos participates in a panel entitled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” for “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2022 New York City” hosted by the Practising Law Institute (PLI).
Description: The panelists review the ethical rules related to advising clients on transactions involving partnerships and other passthrough entities, using a real-life hypothetical, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit. Ethical rules covered by the panelists include standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Panelists

Bryan C. Skarlatos, Partner, Kostelanetz & Fink, LLP; and
Michael J. Desmond, Partner, Gibson, Dunn & Crutcher LLP.

Click here for more information and to register.

Don Fort Participates In The 2022 Government Analytics Leadership Forum For Canadian Government Officials
2022-05-10 09:00 - 10:00 (America/New_York)
On May 10, 2022, Don Fort discusses how tax agencies can shine a light on the shadow economy and address compliance challenges head on, using cloud computing, advanced algorithms, and public data on the web at the 2022 Government Analytics Leadership Forum. Underreporting of business income and sales have been age-old problems for tax agencies around the world, and the digital economy increasingly exacerbates the issue by enabling complicated transactions and blurring the lines between the physical and digital worlds. SAS and IVIX have partnered together to set a bold goal of creating unprecedented economic transparency across the global economy.
Description:
Governments globally are trying to maximize technology benefits to protect and service the public and support crucial investment decisions. But they’re challenged by fraud and improper payments, security threats that can even threaten physical infrastructure, and the inability to obtain insights from the vast quantities of data government organizations produce daily.
Join the 2022 Government Analytics Leadership Forum May 3 and May 10 to learn how SAS and its partners can help the public sector address real challenges brought about by change and an acceleration of technology adoption.
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Caroline D. Ciraolo Participates In A Panel Entitled "Tax Litigation Update including Recent Decisions and their Impact on Corporate and Individual Taxpayers" For The Tax Legislative And Regulatory Update Conference Hosted By The DC Bar
2022-05-04 14:00 - 15:30 (America/New_York)
On May 4, 2022, Caroline D. Ciraolo participates in a panel entitled “Tax Controversy: Tax Litigation Update including Recent Decisions and their Impact on Corporate and Individual Taxpayers” for the Tax Legislative and Regulatory Update Conference hosted by the DC Bar Taxation Community.
Moderator:

Michael Desmond, Partner, Gibson Dunn & Crutcher LLP

Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP and Adjunct Professor of Law, The Georgetown University Law Center
Miriam Fisher, Partner, Latham & Watkins, LLP
Tax Division, U.S. Department of Justice (TBD)

Click here for more information and to register.

Caroline D. Ciraolo Delivers Opening Remarks For A Panel Entitled "Breaking Down Barriers To Effectuate Change in the Legal Field" Hosted By The Federal Bar Association's Section On Taxation
2022-05-04 12:00 - 13:30 (America/New_York)
On May 4, 2022, Caroline D. Ciraolo delivers opening remarks for a panel entitled “Breaking Down Barriers To Effectuate Change in the Legal Field” hosted by the Federal Bar Association’s Section on Taxation.
Description:
In this virtual panel, distinguished justices on the U.S. Tax Court discuss how they navigated the legal field throughout their trail-blazing careers and practices that can lead to a more diverse, inclusive, and equal environment in the legal field.
Opening Remarks:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Drita Tonuzi, Deputy Chief Counsel (Operations), IRS, Office of Chief Counsel

Moderators:

Paulmikell “PM” Fabian, IRS, Office of Chief Counsel
Renan Rodriguez, Weil, Gotshal & Manges, LLP

Panelists:

Hon. Maurice B. Foley, Chief Judge, U.S. Tax Court
Hon. Courtney D. Jones, Judge, U.S. Tax Court
Hon. Juan F. Vasquez, Judge, U.S. Tax Court
Hon. Eunkyong Choi, Special Trial Judge, U.S. Tax Court

Click here to register.

Christopher M. Ferguson Participates In A Panel Entitled “So Your Client Wants to Pay You in Cryptocurrency…” For The New York Law School 19th Annual Tax Lawyering Workshop
2022-04-29 09:15 - 10:30 (America/New_York)
On April 29, 2022, Christopher M. Ferguson participates in a panel entitled, “So Your Client Wants to Pay You in Cryptocurrency…” for the Graduate Tax Program at New York Law School’s 19th Annual Tax Lawyering Workshop: Tax Practice In A Changing World.
The program meets virtually via Zoom and offers Ethics CLE Credits (NY transitional and non-transitional).
Moderator:

Ann F. Thomas, Otto L. Walter Distinguished Professor of Tax Law; Director, Graduate Tax Program, NYLS

Panelists

Christopher M. Ferguson, Partner, Kostelanetz & Fink LLP
Houman Shadab, Professor of Law; Director, Innovation Center for Law and Technology, NYLS
