Caroline Ciraolo Participates In The Panel "Balancing Tax Planning, Advocacy, And Professional Ethics" At Practicing Law Institute's 2019 Tax Strategies Program In Los Angeles, CA
2019-12-06
Caroline D. Ciraolo participates in the panel “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know,” at Practicing Law Institute’s 2019 Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings program in Los Angeles, CA on December 6, 2019.
Tax Strategies 2019 is the most comprehensive and insightful conference you could possibly attend on corporate tax. You receive the very latest information, strategies and practical insights available from leading tax practitioners from law firms, accounting firms, corporations and academia from across the United States, along with policymakers from the IRS.
For more information, click here.

Caroline Ciraolo Participates In The Panel Entitled "Tax Fraud Red Flags" At The ABA/ABA Financial Crimes Enforcement Conference
2019-12-09 - 2019-12-10
Caroline D. Ciraolo participates in the panel entitled “Tax Fraud Red Flags” at the ABA/ABA Financial Crimes Enforcement Conference on December 9 and 10, 2019, in Washington, D.C.

Two powerhouse organizations at the forefront of financial crimes–the American Bankers Association and American Bar Association–partner to deliver this premier educational event that has become a trusted resource for insights, expertise and tactics to protect your bank. In this fast-paced session, you’ll hear about recent FCPA enforcement actions and their impact on your program.
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Caroline Ciraolo Participates In The Criminal Tax Workshop At The 36th Annual National Institute On Criminal Tax Fraud / The 9th Annual National Institute On Tax Controversy In Las Vegas, NV
2019-12-11
Caroline D. Ciraolo participates in the Criminal Tax Workshop at the 36th Annual National Institute on Criminal Tax Fraud / the 9th Annual National Institute on Tax Controversy in Las Vegas, NV, on December 11, 2019.
This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax prosecutions and defense.
Curriculum topics include:

Round-table discussions with senior officials from the IRS and Justice Department
Strategies for experienced practitioners when representing clients in examination, at appeals, and during criminal investigations
Breakout sessions focused on civil tax controversy and criminal tax defense strategies
Advice from judges on what they want to hear from you

For more information, click here.

Michael Sardar Participates On The Panel "Criminal Tax Workshop" At The 36th Annual National Institute On Criminal Tax Fraud/The 9th Annual National Institute On Tax Controversy In Las Vegas, NV
2019-12-12
Michael Sardar participated on the panel “Criminal Tax Workshop” at the 36th Annual National Institute on Criminal Tax Fraud/The 9th Annual National Institute on Tax Controversy in Las Vegas, NV.
This popular workshop teaches strategies and techniques for handling sensitive civil examinations and criminal investigations, and defending a criminal prosecution. The workshop addresses when to anticipate a criminal referral, IRS Special Agent interviews of the taxpayer or preparer, representation of a target, subject or witness in a criminal investigation, how to approach a Department of Justice conference, procedural and trial issues that every criminal tax defense attorney should know, when and how to argue tax loss issues, effective plea negotiations, and sentencing strategies. The workshop includes a “criminal tax toolkit” of practice tips prepared by experienced practitioners.
For more information, please click here.

Caroline Ciraolo Participates On The Panel "The Consequences Of Conviction" At The 36th Annual National Institute On Criminal Tax Fraud / The 9th Annual National Institute On Tax Controversy In Las Vegas, NV
2019-12-12
Caroline D. Ciraolo participates on the panel “The Consequences of Conviction: The Sentencing Guidelines, Restitution, Forfeiture, and Other Bad Things That Happen,” at the 36th Annual National Institute on Criminal Tax Fraud / the 9th Annual National Institute on Tax Controversy in Las Vegas, NV, on December 12, 2019.
This program brings together together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax prosecutions and defense.
Curriculum topics include:

Round-table discussions with senior officials from the IRS and Justice Department
Strategies for experienced practitioners when representing clients in examination, at appeals, and during criminal investigations
Breakout sessions focused on civil tax controversy and criminal tax defense strategies
Advice from judges on what they want to hear from you

For more information, click here.

Sharon L. McCarthy Participates On The Panel "Mental Defense To Tax Crimes – Declination Or Mitigation” At The 36th Annual National Institute On Criminal Tax Fraud/The 9th Annual National Institute On Tax Controversy In Las Vegas, NV
2019-12-13
Sharon L. McCarthy participates on the panel “Mental Defense to Tax Crimes – Declination or Mitigation” at the 36th Annual National Institute on Criminal Tax Fraud/The 9th Annual National Institute on Tax Controversy in Las Vegas, NV.
Tax crimes are specific intent crimes—requiring the violation of a known legal duty. The panel will explore when a potential mental impairment should be considered as a defense or as mitigation in sentencing. For more information about this event, please click here.

Michael Sardar Presents "The Updated IRS Voluntary Disclosure Practice" At The Long Island University Tax Controversy Forum On January 16, 2020
2020-01-16
On January 16, 2020, Michael Sardar presented “The Updated IRS Voluntary Disclosure Practice” at the Long Island University Tax Controversy Forum.
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Usman Mohammad Participates In A Webinar Entitled "U.S. Tax Reporting Of Foreign Retirement Accounts And Other Foreign Trusts" Hosted By Strafford On January 23, 2020
2020-01-23
Usman Mohammad participated in the webinar entitled “U.S. Tax Reporting of Foreign Retirement Accounts and Other Foreign Trusts” hosted by Strafford on January 23, 2020.
This webinar covered tax considerations for individuals with interests in foreign retirement accounts and trusts and will benefit accountants, attorneys, and investment professionals serving these clients. The webinar went beyond the basics to offer useful practice pointers on how the IRS approaches foreign pensions in an examination situation to prevent potentially costly tax penalties and sanctions. It covered Americans’ interests in United Kingdom retirement plans, as they are most commonly encountered in practice.
For more information, please click here.

Megan Brackney Participates In A Panel Entitled “Empire State Update: Recent Developments In New York State Taxes,” New York State Bar Association, Section Of Taxation, Annual Meeting
2020-01-28
The panelists discuss recent developments, including an update on New York’s draft corporate income tax regulations, newly issued administrative guidance, as well as some important decisions issued by the New York State Division of Tax Appeals and New York State judicial courts.
Panel Chair: Jack Trachtenberg, Esq., Deloitte Tax LLP, New York, NY
Panelists: Megan L. Brackney, Esq., Kostelanetz & Fink LLP, New York, NY; Deborah R. Liebman,Esq., Deputy Counsel, Office of Counsel, New York State Department of Taxation and Finance, Albany, NY [Invited]; Alysse B. McLoughlin, Esq., McDermott Will & Emery LLP, New York, NY
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Christopher Ferguson Presents The "Update On International Voluntary Disclosure Procedures" At The NYSSCPA’s International Tax Committee’s Annual Conference
2020-01-30
An overview of the current options in place for those US taxpayers who have not complied with return filings and/or information disclosures, recent activities/focus by the IRS on enforcement, and traps for the unwary.
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Caroline Ciraolo Moderates The Panel Entitled "Update: Tax Division, U.S. Department Of Justice," At The Midyear Meeting Of The American Bar Association Section Of Taxation In Boca Raton, FL
2020-02-01
The Midyear Meeting of the American Bar Association Section of Taxation in Boca Raton, Florida offers individuals the opportunity to learn from leaders in taxation over the course of three days: January 30 – February 1, 2020. During the panel “Update: Tax Division, U.S. Department of Justice” on February 1, moderator Caroline D. Ciraolo speaks with Panelist Richard Zuckerman, Principal Deputy Assistant Attorney General, Tax Division, Department of Justice, Washington, DC, about updates at the Department of Justice’s Tax Division.
For more information, please click here.

Caroline Ciraolo Presents "Women In Tax" At Georgetown University Law Center
2020-02-12
Caroline D. Ciraolo presents “Women in Tax” at Georgetown University Law Center on February 12, 2020.

Caroline Ciraolo And Jay Nanavati Present "Financial Crimes Enforcement, Compliance & Risk Mitigation" At The Bahamas Financial Services Board In Nassau, Bahamas
2020-02-19
Washington, D.C.-based Kostelanetz & Fink partners Caroline D. Ciraolo and Jay R. Nanavati present “Financial Crimes Enforcement, Compliance & Risk Mitigation” at the Bahamas Financial Services Board in Nassau, Bahamas on February 19, 2020.

Megan Brackney Presents A Webinar Entitled “IRS Summons: Use, Scope, And Enforcement In 2020” For CPA Academy
2020-02-20
The IRS has various methods of obtaining information from and about taxpayers. In this program, attorney Megan L. Brackney discusses the IRS’s use of summonses to obtain information from taxpayers and third parties, the scope of the IRS’s authority, and summons enforcement. The discussion will include the IRS’s use of John Doe Summonses and Formal Document Requests. We will also discuss taxpayer rights and defenses, including the assertion of privileges, such as attorney-client, work product, federally-authorized tax practitioner, and Fifth Amendment privileges.
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Caroline Ciraolo Participates In The Forum On International Tax Disputes, Surrey, United Kingdom
2020-02-26 - 2020-02-28
Each year the Forum’s steering committee welcomes up to 44 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 use of aggressive techniques like criminal investigations and digital taxation on the rise, there is a greater need to keep up-to-date on developments in key jurisdictions around the world.
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Caroline Ciraolo Co-Chairs The Enforcement & Criminal Tax Program At The Federal Bar Association's 2020 Tax Law Conference
2020-03-05 - 2020-03-06
Caroline D. Ciraolo co-chairs the Enforcement & Criminal Tax Program at the Federal Bar Association’s 2020 Tax Law Conference, on March 5 and March 6, 2020.
Panel topics include “Avoiding or Not Avoiding Evasion of Payment Prosecutions and the Civil Aftermath,” “Use of Data Analytics in Criminal Tax Investigations,” “Navigating Virtual Currency Compliance: A Civil and Criminal Perspective,”Criminal Tax Sentencing – Best Practices,” and ” A View from the Services and Enforcement Leaders.”

Robert Russell Participates In A Panel Entitled "Outbound Tax Developments" At The Federal Bar Association's 2020 Tax Law Conference
2020-03-06
The TCJA made significant changes to how income of controlled foreign corporations is taxed. The operation of the new Global Intangible Low-Taxed Income (GILTI) continues to be molded as guidance is released related to foreign tax credits, previously taxed earnings and profits and foreign-derived intangible income.
Topics discussed:
• Guidance related to foreign tax credit.
• Address the current status of previously taxed earnings & profits (PTEP).
• Explore the impact of the foreign-derived intangible income (FDII) provision and accompanying regulations.
Brandon King, Associate, Baker & McKenzie LLP (moderator)
John Bates, Principal, Deloitte Tax LLP
Robert Russell, Counsel, Kostelanetz & Fink, LLP
Jeffrey L. Parry, Senior Counsel, I.R.S. Office of Chief Counsel (INTL)
James Wang, Attorney-Advisor, U.S. Department of the Treasury
Jason Yen, Attorney-Advisor, U.S. Department of the Treasury
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Michael Sardar Participates In The Panel Entitled "When A Civil Audit Turns: Navigating An Audit When The Mistakes Are Not So Unintentional" At The Federal Bar Association's 2020 Tax Law Conference
2020-03-06
Tax practitioners, even those who operate primarily in the civil space, should understand the procedures of criminal investigations and the warning signs (both from the client and the government) that a criminal referral is looming. This panel discussed issues that have the potential to influence an I.R.S. examiner’s decision to refer an audit for criminal investigation and offered practitioners tips to navigate those issues, either to avoid referral or to manage the process after a case turns criminal. This panel offered useful insights from both the civil and the criminal tax practitioner perspective.
Topics discussed:
• Protecting privilege while still cooperating fully with the administrative process – and how to remain an engaged advocate for your client without obstructing justice.
• Learning to recognize the warning signs that a referral may be imminent – and what to do next if you suspect an audit will become criminal.
• Knowing when to advise your client to claim the Fifth Amendment – and what that means to the resolution of the case.
Dianne C. Mehany, Member, Caplin & Drysdale Chartered (moderator)
Michael C. Boteler, Trial Attorney, U.S. Department of Justice, Tax Division
Michael Sardar, Partner, Kostelanetz & Fink, LLP
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Caroline D. Ciraolo Participates In A Panel Entitled "Ethics, Data Breaches, And More," At The Federal Bar Association's 2020 Tax Law Conference
2020-03-06
This panel touches on a variety of ethics issues including those arising from limited representation of a client, from service as a personal representative under unified partnership audit procedures, and from a data breach.
Topics include:
• The ethical rules pertaining to limited representations of clients in tax matters, including in connection with the Tax Court’s recently released limited representation rules.
• The ethical considerations when contemplating serving as a partnership representative or designated individual under the BBA audit regime, particularly with respect to navigating conflicts of interest between the partners and the partnership.
• How to address data breaches and loss of client information and the requirements under the ABA model rules and other rules for timely addressing these issues.
Jeremiah Coder, Director, Global Tax Policy, PwC (moderator)
Jennifer Auchterlonie, Special Counsel, I.R.S. Office of Chief Counsel (P&A)
Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Ashton “Hap” Trice, Deputy Associate Chief Counsel, I.R.S. Office of Chief Counsel (P&A)
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Caroline D. Ciraolo Moderates And Brian P. Ketcham Participates In The Panel Entitled "Criminal Tax Sentencing - Best Practices," At The Federal Bar Association's 2020 Tax Law Conference
2020-03-06
The panel reviews the latest sentencing statistics in criminal tax prosecutions and discusses best practices in connection with negotiating plea agreements, calculation of tax loss, impact of forfeiture, dealing with the Office of Probation and Pretrial Services, character letters, payment of restitution, sentencing memoranda, allocutions, witnesses, conditions of probation or supervised release, and designations.
Learning Objectives:
• Overview of latest criminal tax sentencing statistics/outcomes.
• Best practices in negotiating plea agreements.
• Sentencing concerns, including, tax loss calculations, forfeiture, restitution payment, character letters, allocutions, etc.

Megan Brackney Presents A Webinar Entitled "The New IRS Fraud Enforcement Office: Enforcement & Consequences Of Tax Fraud," For The CPA Academy
2020-04-07
Now is a good time to enhance your understanding of tax fraud and the IRS’s antifraud enforcement tools The IRS has created a new Fraud Enforcement Office to develop increased enforcement, both with criminal referrals from the field and additional civil fraud penalties. This webinar discusses the indicia of fraud, how the IRS identifies and proves fraud, and the civil and criminal consequences of tax fraud, and the relevant procedures.
Learning Objectives:

Learn the elements of tax fraud and the IRS’s methods of proving tax fraud
Identify “badges of fraud” in your clients’ case
Learn about the civil and criminal consequences to taxpayers who commit tax fraud
Learn about methods to remediate tax fraud and avoid adverse consequences for your clients

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Megan Brackney Presents A Webinar Entitled "Form 8300 Reporting Requirements And Penalties" For The CPA Academy
2020-05-13
This program discusses the requirements to file Forms 8300 to report cash transactions in a trade or business of over $10,000 and to furnish annual statements to customers. Ms. Brackney outlines the basics of Form 8300 compliance, and then goes into further discussion about the potential penalties, defenses to penalties, and the methods of challenging Form 8300 penalties.
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Megan Brackney Presents A Webinar Entitled "IRS Summons And Other Methods Of Obtaining Taxpayer Information, Enforcement, And Defenses" For Celesq Attorneys Ed Center
2020-05-21
The IRS has several methods for obtaining information about taxpayers. This program discussed the IRS’s methods of obtaining information, focusing primarily on the IRS’s summons authority, including the scope of that authority, taxpayer’s rights and privileges, summons enforcement litigation, and the attorney’s ethical obligations when responding to IRS requests for information under Circular 230.

Learning Objectives:
1. Understand the methods that the IRS uses to gather information from and about taxpayers.
2. Discuss the methods of enforcement of IRS summons and defenses to enforcement.
3. Examine the potential defenses and privileges that may limit the IRS’s ability to obtain information.
4. Understand the lawyer’s ethical obligations when responding to an IRS request for information

Nicholas S. Bahnsen Moderates An American Bar Association Panel Entitled "Ethical Obligations And Covid19: What Tax Practitioners Need To Know" On June 4, 2020
2020-06-04
What should we be on the lookout for to ensure we are not helping our clients participate in or become the victim of fraud considering the CARES Act? How should practitioners ensure we are meeting both IRS and court deadlines? How should we ensure we are meeting our ethical obligations to communicate with our clients? Nicholas S. Bahnsen moderated a panel discussing these timely issues.
Panel:

Guinevere Moore, Moore Tax Law Group LLC, Chicago, IL
Matt Cooper, Deloitte Tax LLP, Washington, DC
Kathy Enstrom, Internal Revenue Service’s Criminal Investigations, Washington, DC
Judge Ronald L. Buch, US Tax Court, Washington, DC
Pamela Wilson Fuller, Office of Chief Counsel IRS, Washington, DC
Nicholas Bahnsen, Kostelanetz & Fink LLP, New York, NY (Moderator)

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Robert M. Russell Participates In A Panel Entitled "Tax Day 2020: Filing And Payment Deadlines" At The ABA Section Of Taxation's Virtual May Meeting On June 10, 2020
2020-06-10
Robert Russell participated in the “Tax Day 2020: Filing and Payment Deadlines” panel at the American Bar Association Section of Taxation’s Virtual May Meeting on June 10, 2020.
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Caroline Ciraolo Co-chairs & Moderates A Webinar On International Criminal Tax Enforcement For ABA’s Virtual 20th U.S. And Europe Tax Practice Trends Conference
2020-07-07
Caroline D. Ciraolo co-chairs and moderates a panel entitled “Following the Money (including digital currency) – The Current State of International Criminal Tax Enforcement.” The panel provides updates and current statistics on international criminal tax enforcement from IRS-CI and the Justice Department and discusses recent international criminal tax investigations and prosecutions, including those involving the use of virtual currency.
International tax compliance and enforcement continue to be top priorities of tax authorities around the world. Either working within their own jurisdiction or across borders, governments are actively pursuing those individuals and entities intent on evading their tax obligations and, in doing so, depriving those governments of much needed revenue. For example, in the United States, cross border investigations are often the most complex and time consuming matters pursued by IRS Criminal Investigation. These investigations are supported by attaches, deputy attaches, and investigative aides based in 11 countries. From FY 2013 through FY 2019, IRS-CI recommended more than 1,000 international tax prosecutions. In addition, the U.S. Department of Justice Tax Division has negotiated more than 100 non-prosecution agreements, deferred prosecutions, and guilty pleas with foreign financial institutions. The panelists provided updates and current statistics on international criminal tax enforcement from IRS-CI and the Justice Department and discussed recent international criminal tax investigations and prosecutions, including those involving the use of virtual currency.
Panelists:

Caroline D. Ciraolo, Kostelanetz & Fink, LLP, Washington, DC
Thierry Marembert, Kiejman & Marembert, Paris
Nanette Davis, Senior Litigation Counsel, Tax Division, U.S. Department of Justice, Washington, DC
Don Fort, Chief, Criminal Investigation, IRS, Washington, DC
Sarah E. Paul, Eversheds Sutherland, New York, NY
Nicolai B. Sørensen, Lundgrens, Hellerup
Sabine Stetter, Stetter Attorneys at Law, Munich

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Caroline Ciraolo Chairs The Civil And Criminal Tax Penalties Committee Virtual May Meeting For The American Bar Association’s Section Of Taxation
2020-07-14 13:00 - 16:00 (America/New_York)
The event consists of three-hours of programming presenting a series of panels including: update from IRS Criminal Investigation office, update from U.S. Department of Justice Tax Division, disclosure of non-tax crimes, and tax shelters.

1:00 PM – 1:30 PM
Update: IRS Criminal Investigation. An update on current developments and hot topics from the perspective of top officials at the Internal Revenue Service and Department of Justice.
Moderator:
Niles Elber, Caplin & Drysdale, Chtd.
Speaker:
Don Fort, Criminal Investigation, Internal Revenue Service, Washington, DC
1:30 PM – 2:00 PM
Update: Tax Division, U.S. Department of Justice.
Moderator:
Kathy Keneally, Jones Day, New York, NY (Moderator)
Speaker:
Richard E. Zuckerman, Principal Deputy Assistant Attorney General, Tax Division, U.S. Department of Justice, Washington, DC
2:00 PM – 3:00 PM
When You Need to Disclose More Than Just a Tax Crime. Under the IRS voluntary disclosure practice, in exchange for a timely, accurate, and complete disclosure and full cooperation during the associated audit, the IRS will not refer the taxpayers to the U.S. Department of Justice for criminal investigation and prosecution. But what if your client committed non-tax offenses that don’t require a referral from the IRS? What is the risk that the IRS will share the information with another federal agency, who may choose to prosecute? Will the voluntary disclosure protect a taxpayer from prosecution for hiring or harboring undocumented workers, failing to file Forms 8300, or other non-tax criminal conduct? Panelists will review frequent dilemmas faced when a client engages in criminal conduct outside of the Internal Revenue Code, options available to address these issues, how the IRS will treat, and whether it will disseminate, such information received through a voluntary disclosure, and best practices in these cases.
Panelists:
Michelle F. Schwerin, Capes Sokol, St. Louis, MO (Moderator)
D. Richard (Rick) Goss, Acting Director, International Operations, Criminal Investigation, Internal Revenue Service
Carolyn A. Schenck, Assistant Division Counsel (International), Small Business/Self-Employed Division, Office of Chief Counsel, Internal Revenue Service
Sandra Brown, Hochman Salkin Toscher & Perez PC, Beverly Hills, CA
Grace E. Albinson, Trial Attorney, Tax Division, U.S. Department of Justice
3:00 PM – 4:00 PM
Tax Shelters – The Current Generation. The IRS continues to combat abusive tax shelters and transactions, often shutting down one group of shelters only to have others surface using different theories and schemes to avoid or evade tax due and owing. This panel will address the range of abusive domestic tax shelters that are presenting current and emerging tax enforcement challenges and how today’s shelters compare to the flood of corporate tax shelters two decades ago. The panelists will discuss current promotions and the nature and impact of the government’s response, including the assessment and deterrent effect of civil penalties, referrals of advisors to the Office of Professional Responsibility, and criminal investigations and prosecutions.
Panelists:
Miriam Fisher, Latham & Watkins (Moderator)
Tom Cullinan, Counselor to the Commissioner and to Chief Counsel, Internal Revenue Service
Sharyn Fisk, Director, Office of Professional Responsibility
David A. Hubbert, Deputy Assistance Attorney General (Civil Matters), Tax Division, U.S. Department of Justice
Brendan O’Dell, Coordinator, Promoter Investigations Coordinator, Office of the Deputy Commissioner, Services and Enforcement, Internal Revenue Service

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Caroline Ciraolo Participates In The FBAR Litigation Developments Webinar Panel For STEP USA
2020-07-16
The IRS and DOJ have been aggressive in pursuing judicial recourse to enforce and seek collection of FBAR assessments. STEP USA’s webinar addresses the key issues and considerations in the litigation of an FBAR case. The format for the presentation was an interactive question and answer format among the knowledgeable panelists. There was an opportunity for attendees to pose questions to the panelists.
Caroline Ciraolo, Partner, Kostelanetz & Fink, LLP, Washington, DC and Baltimore, MD. Ms. Ciraolo is former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division. She represents individuals and entities in civil tax controversies, including sensitive audits, administrative appeals, and litigation, evaluating tax compliance options, internal investigations, and criminal tax investigations and prosecutions. During her tenure, the Tax Division reached agreements with 80 Swiss financial institutions that facilitated tax evasion and the avoidance of reporting requirements by U.S. account holders, and pursued suits to collect and defended challenges to FBAR penalties assessed by the IRS. Ms. Ciraolo is Vice President of the American College of Tax Counsel, Chair of the Civil & Criminal Tax Penalties Committee of the ABA’s Section of Taxation, and an Adjunct Professor at Georgetown University Law Center (International Tax Controversies, Tax Fraud and Tax Crimes) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes).
Jeffrey Neiman, Founding Member, Marcus Neiman Rashbaum, Ft. Lauderdale, FL. Mr. Neiman is an experienced trial lawyer who regularly defends individuals and corporations in white collar criminal litigation, matters involving tax controversies, government regulatory enforcement matters, internal investigations, compliance counseling, and complex civil litigation. An alum of the United States Department of Justice Attorney General’s Honors Program, he began his career working for the Department of Justice Tax Division and then the Criminal Division, Fraud Section in Washington, D.C. He then served as an Assistant United States Attorney for the Southern District of Florida, where he received national recognition for handling complex, high profile matters including the ground-breaking and historic prosecution of Switzerland’s largest bank, UBS AG, for aiding American citizens to commit tax fraud.
Nicole M. Elliott, Partner, Holland & Knight, Washington, DC. Ms. Elliott is a tax attorney in Holland & Knight’s Public Policy & Regulation Group. Among her practice areas, Ms. Elliott advises clients on tax controversy matters, both at the administrative level and in litigation. Prior to joining Holland & Knight, Ms. Elliott was a tax litigator for the U.S. Department of Justice, Tax Division and a U.S. Treasury Department Executive and member of the senior executive team with the Internal Revenue Service, acting as Senior Advisor to Commissioner John A. Koskinen.
William M. Sharp, Sr. Partner, Holland & Knight, Atlanta, GA, Tampa, FL & San Francisco, CA. Mr. Sharp represents clients in a wide variety of international tax planning and tax controversy cases. He provides international and domestic tax advice to numerous U.S.-based and foreign-based clients, including publicly traded and closely held entities. His tax practice also focuses on globally oriented high-net-worth clients, including U.S. and foreign-based family offices. Mr. Sharp has served as lead counsel with respect to U.S. Tax Court, Internal Revenue Service (IRS) appeals and examination cases. He also has served as lead counsel or co-counsel to well over 1,000 IRS voluntary disclosure cases.
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Bryan Skarlatos Participates In The Fifth Annual USD School Of Law - RJS Law Tax Controversy Virtual Institute Panel On July 17, 2020
2020-07-17
Bryan Skarlatos participated in this year’s USD School of Law – RJS Law Tax Controversy Institute, which was held virtually July 17, 2020, 10:30am – 2:35 pm (PST).
The region’s top tax attorneys, government agency officials, and law school professors discussed topics including handling tax controversy during COVID- 19, fraud enforcement and criminal investigations. Mr. Skarlatos participated on a panel entitled “IRS New Emphasis on Fraud Enforcement and Criminal Investigation.”
Steven Toscher, Principal, Hochman, Salkin, Toscher, & Perez P.C., and Miranda Perry Fleischer, Professor of Law and Co-Director of Graduate Tax Programs, USD School of Law kicked off the conference with introductory remarks.
Other speakers and panelists included:
John D. (Don) Fort, Chief Criminal Investigation, IRS
Richard Carpenter, Richard Carpenter Tax Law Office
Hon. Emin Toro, Judge, United States Tax Court
Sharyn Fisk, Director, Office of Professional Responsibility, Internal Revenue Service, was the keynote speaker.
The event also featured the presentation of the Richard Carpenter Award to M. Carr Ferguson. The award is given to individuals who personify honesty, integrity, ethics, and compassion throughout his/her careers in the field of tax controversy and have demonstrated outstanding dedication and expertise while representing taxpayers before the federal and state governments.
This year’s Virtual Institute was brought to attendees at no cost. The hosts continue to encourage your support of USD School of Law Tax Law Student Scholarship Fund, especially this year in light of the growing impact of COVID-19.
Materials and the Zoom link were sent to the email provided during registration. If you have any questions about the event, please email usdlawevent@sandiego.edu.
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Christopher M. Ferguson Conducts A CLE On Cares Act Enforcement With Celesq® AttorneysEd Center In Partnership With Thompson/Reuters (West)
2020-07-28
On July 28, 2020, Christopher M. Ferguson conducts a CLE on CARES Act Enforcement with Celesq® AttorneysEd Center in partnership with Thompson/Reuters (West).
With the passage of the CARES Act, Congress launched an unprecedented, multi-trillion stimulus package into the economy at break-neck speed in order to address the coronavirus pandemic. History has shown that massive government programs prove irresistible to fraudsters. Drawing on lessons from one of the last major stimulus programs, the TARP program, this presentation focused on governmental efforts to deter, detect and punish fraud and other criminality under the CARES Act, with a particular focus on the Payroll Protection Program.
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