Henry Stow Lovejoy Participates In A Webinar Entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” For Strafford Publications
2021-08-03 13:00 - 14:50 (America/New_York)
On August 3, 2021, Henry Stow Lovejoy participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford Publications.
Course Description:
Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, is one of the most complicated forms of all U.S. filing requirements concerning foreign persons. Initially, the reporting obligations applied to corporations only; now the requirements extend to DREs active in the U.S. owned by non-U.S. individuals and corporations.
IRC 6038A, IRC 6038C, and the regulations thereunder require a “reporting corporation” to disclose specified “reportable transactions” it has with any “related parties” on Form 5472. Defining these elements is highly sophisticated, so tax advisers must have a thorough grasp of each aspect to ensure that the taxpayer has disclosed all reportable transactions and met the record maintenance requirements to support its tax position for these transactions.
In response to scenarios in which foreign individuals and corporations were conducting business in the U.S. through DREs to avoid information reporting, the Service now requires foreign-owned single-member LLCs and other DREs to file Form 5472.
Foreign persons owning a U.S. domestic DRE, either directly or indirectly through attribution rules, must obtain necessary taxpayer-identification numbers and disclose reportable transactions. Penalties for failing to file Form 5472 are $25,000 per failure, with complicated rules for penalty mitigation.
Listen as our experienced panel provides a thorough and practical guide to completing Form 5472, including key definitions and a discussion of the expanded filing requirements.
Speakers:
Henry Stow Lovejoy, Kostelanetz & Fink, LLP
John Samtoy, Holthouse Carlin & Van Trigt LLP
Click here for more information and to register.

Don Fort Participates In A Webcast Entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” For The New York City Bar Association
2021-08-05 18:00 - 19:30
On August 5, 2021, Don Fort participates in a webcast entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” for the New York City Bar Association.
Description: The CLE will include an in depth discussion of hot topics in the taxation of virtual currency. The panelists, both current and former IRS Office of Chief Counsel attorneys and professionals, will provide tips and guidance on compliance and reporting issues and navigating IRS audits and information requests. The panel will also discuss IRS initiatives to investigate tax crimes involving virtual currency, and recent IRS developments and official guidance.
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Stephen A. Josey Co-Chairs And Moderates A Webcast Entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” For The New York City Bar Association
2021-08-05 18:00 - 19:30
On August 5, 2021, Stephen A. Josey co-chairs and moderates a webcast entitled “Taxation of Virtual Currency and IRS Enforcement Initiatives” for the New York City Bar Association.
Description: The CLE will include an in depth discussion of hot topics in the taxation of virtual currency. The panelists, both current and former IRS Office of Chief Counsel attorneys and professionals, will provide tips and guidance on compliance and reporting issues and navigating IRS audits and information requests. The panel will also discuss IRS initiatives to investigate tax crimes involving virtual currency, and recent IRS developments and official guidance.
Click here for more information and to register.

Caroline D. Ciraolo Participates In A Panel Entitled “Voluntary Disclosure Practice 2021 and Beyond” For The Texas Bar’s 39th Annual Tax Law: Practicing Tax Law In Uncertain Times Program
2021-08-20 15:00 - 16:00
On August 20, 2021, Caroline D. Ciraolo participates in a panel entitled “Voluntary Disclosure Practice 2021 and Beyond” for the Texas Bar’s 39th annual Tax Law: Practicing Tax Law in Uncertain Times program.
Description: In light of the current and anticipated increase in civil and criminal tax enforcement, Caroline Ciraolo and Daniel Price review the IRS Relief Procedures for Former U.S. Citizens and the current Voluntary Disclosure Practice, including extensive updates to the Internal Revenue Manual provisions that address eligibility, the lookback period and penalty framework, cooperation requirements, and revocation procedures.
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Don Fort Delivers Keynote Speech For The 38th International Symposium On Economic Crime
2021-09-06 03:00 - 06:00
On September 6, Don Fort delivers a keynote address for the 38th International Symposium on Economic Crime.
Description: The 38th International Symposium on Economic Crime at Jesus College, Cambridge brings together from across the globe a unique level and depth of expertise to address one of the biggest threats facing the stability and development of all our economies. The overarching theme for this year’s symposium focuses on who is actually harmed and pays for economically motivated crime and who should be held more accountable.
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Don Fort Participates In Plenary Workshop Entitled "The Cost of Cheating: US and UK Enforcement to Deter Non-Compliance" For The 38th International Symposium On Economic Crime
2021-09-07 09:00 - 10:45
On September 7, Don Fort participates in a plenary workshop entitled “The Cost of Cheating: US and UK Enforcement to Deter Non-Compliance” for the 38th International Symposium on Economic Crime.
Description: The 38th International Symposium on Economic Crime at Jesus College, Cambridge brings together from across the globe a unique level and depth of expertise to address one of the biggest threats facing the stability and development of all our economies. The overarching theme for this year’s symposium focuses on who is actually harmed and pays for economically motivated crime and who should be held more accountable. In this workshop, Don Fort is joined by:

Mr Ian M. Comisky, Partner, Fox Rothschild LLP, Philadelphia and former Assistant US Attorney, Southern District of Florida, USA
Mr Simon York, Director, Fraud Investigation Service, HM Revenue and Customs, UK
Mr Larry A. Campagna, Partner, Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, USA
Ms Zhanna A. Ziering, Partner, Caplin and Drysdale Attorneys, New York, USA

Click here for more information.

Caroline D. Ciraolo Moderates A Panel Entitled “Compliance Initiatives and Voluntary Disclosure Practice – Perspectives and Updates from Puerto Rico's Hacienda and the IRS” For The ABA Section Of Taxation
2021-09-09 13:00 - 15:10
On September 9, 2021, Caroline D. Ciraolo moderates a panel entitled “Compliance Initiatives and Voluntary Disclosure Practice – Perspectives and Updates from Puerto Rico’s Hacienda and the IRS” for the American Bar Association Section of Taxation.
Description: In light of the current and anticipated increase in civil and criminal tax enforcement, and the new IRS campaign to address taxpayers who have claimed benefits through Puerto Rican residency programs, this panel reviews the history of Puerto Rico Acts 20 and 22, the use and abuse of these residency programs, potential civil penalties, current enforcement efforts, and potential paths to compliance, including a review of the current Voluntary Disclosure Practice. Panelists include key personnel within the Internal Revenue Service and Departamento de Hacienda de Puerto Rico.
Moderator:
Caroline Ciraolo, Kostelanetz & Fink, LLP
Speakers:
Daniel N. Price, IRS Office of Chief Counsel
Ladd C. Brown, IRS Office of Chief Counsel
Roxanna Santiago Ortiz, Hacienda
Angel Pantoja Rodríguez, Hacienda
Mildred Valentin Alvarez, Hacienda
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Bryan C. Skarlatos Participates In A Program Entitled "The Anti-Money Laundering Act of 2020: A Review of Selected Provisions" For Lawline
2021-09-10 14:30 - 16:00
On September 10, 2021, Bryan C. Skarlatos participants in a program entitled “The Anti-Money Laundering Act of 2020: A Review of Selected Provisions” for Lawline.
On January 1, 2020, over a Presidential veto, Congress passed the Defense Appropriations Act. Included in the Act, at Subpart F, is the Anti-Money Laundering (AML) Act of 2020. The Act is the first set of amendments to the Bank Secrecy Act and related statutes in over 50 years. The Act contains major changes, including a Corporate Transparency Act, treatment of cryptocurrency, regulation of sales in antiquities, and upcoming changes to Know Your Customer (KYC), suspicious activity reporting, and related requirements for regulated entities. The program, taught by tax attorneys Ian Comisky and Bryan Skarlatos, will discuss the highlights of the changes currently affecting practitioners this year and in the years to come.
Panelists:
Bryan C. Skarlatos, Kostelanetz & Fink, New York, NY
Ian M. Comisky, Fox Rothchild, Philadelphia, PA
Click here for more information and to register.

Bryan C. Skarlatos Participates In A Program Entitled "Attorney-Client Privilege and Work Product Doctrine in an Era of Increased Tax Enforcement"
2021-09-15 12:00 - 13:00
On September 15, 2021, Bryan C. Skarlatos participates in a program entitled “Attorney-Client Privilege and Work Product Doctrine in an Era of Increased Tax Enforcement.”
Panelists:
Bryan C. Skarlatos, Kostelanetz & Fink, New York, NY
Ian M. Comisky, Fox Rothchild, Philadelphia, PA

Usman Mohammad Participates In A Webinar Entitled “FATCA Reporting: Filing Form 8938 for Taxpayers With Foreign Assets, Integrating Latest IRS Guidance” For Strafford's CPE Program
2021-09-15 13:00 - 14:50
On September 15, 2021, Usman Mohammad participates in a webinar entitled “FATCA Reporting: Filing Form 8938 for Taxpayers With Foreign Assets, Integrating Latest IRS Guidance” for Strafford’s CPE Program.
Description: This webinar will provide tax advisers with a practical guide to the Foreign Account Tax Compliance Act (FATCA) reporting for taxpayers holding foreign assets. The panel will define reportable specified foreign assets, discuss valuation issues, and offer thorough instruction on completing Form 8938, Statement of Specified Foreign Assets. The webinar will explain the latest changes to Form 8938 and review IRS guidance for reporting requirements.
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Don Fort Participates In A Forbes Panel Entitled “Crypto & Taxes: What You Need to Know”
2021-09-21 14:30 - 15:45
On September 21, 2021, K&F Director of Investigations Don Fort participates in a webinar panel entitled “Crypto & Taxes: What You Need to Know” for Forbes.
Description: With the astonishing rise in the value of Bitcoin and Ethereum, crypto investors and enthusiasts may have serious tax questions on their minds. The Internal Revenue Service (IRS) is also stepping up enforcement efforts to ensure stricter compliance. So if you hold crypto assets (including NFTs) or have traded them or are planning to buy, sell or trade them, what do you need to consider to make sure you don’t run afoul of the law?
Steve Ehrlich, Director of Research & Digital Assets at Forbes Media, moderates a discussion of all the important tax considerations crypto holders need to be aware of well before the end of the year.
Panelists:

Don Fort – Director of Investigations, Kostelanetz & Fink LLP
Steven Ehrlich – Director of Research & Digital Assets, Forbes Media LLC
Kristin Smith – Executive Director, Blockchain Association
Lawrence Zlatkin – Vice President of Tax, Coinbase
Shehan Chandrasekera – Head of Tax Strategy, CoinTracker

Register for free here.

Caroline D. Ciraolo Participates In A Panel Entitled “Promoting Diversity, Equity, and Inclusion in Tax: Ideas and Resources for Mentoring Diverse Students and Leading Discussions of DEI in Tax” For The ABA Section Of Taxation's Virtual Fall Meeting
2021-09-22 12:30 - 14:00
On September 22, 2021, Caroline D. Ciraolo participates in a panel entitled “Promoting Diversity, Equity, and Inclusion in Tax: Ideas and Resources for Mentoring Diverse Students and Leading Discussions of DEI in Tax” for the American Bar Association Section of Taxation’s Virtual Fall Meeting. The meeting is a five-day event led by the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.
Description: This panel documents the need for greater diversity in the field of tax law − in practice and in Academia – and shares ideas to promote this goal, with a focus on law students and recent law school graduates. The panelists (1) provide information about existing programs to promote DEI in the tax profession, (2) discuss ways to build the tax profession pipeline, to recruit and retain diverse tax attorneys, and to provide strong platforms for professional success, and (3) solicit audience participation and ideas for new initiatives.
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Caroline D. Ciraolo Participates In A Panel Entitled “John Doe Summonses: The Tool to Close the Crypto Compliance Gap and Implications for Privilege” For The ABA Section Of Taxation's Virtual Fall Meeting
2021-09-22 14:30 - 16:00
On September 22, 2021, Caroline D. Ciraolo participates in a panel entitled “John Doe Summonses: The Tool to Close the Crypto Compliance Gap and Implications for Privilege” for the American Bar Association Section of Taxation’s Virtual Fall Meeting. The meeting is a five-day event led by the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.
Description: A John Doe Summons allows the IRS, with court approval, to obtain information from a third-party about a class of taxpayers. The IRS’s use of these summonses to identify account holders of UBS made headlines in 2008. Since then, the IRS has expanded the use of John Doe Summonses as an available investigatory tool, including on domestic cryptocurrency exchanges. This panel will recount the historical use of John Doe Summonses by the IRS; examine areas in which the IRS is currently employing these summonses and where they can be used in the future; and discuss important privilege issues that may raise, an example of which is currently pending before the U.S. Supreme Court in Taylor Lohmeyer Law Firm v. United States (Docket 20-1596). The panel’s participants are as follows:
Moderator

Victor Jaramillo, Caplin & Drysdale, Washington D.C.

Panelists

Honorable Steven D. Grimberg, United States District Judge, Northern District of Georgia;
Lawrence Hill, Steptoe & Johnson, New York, NY;
Jeffrey Neiman, Marcus Neiman Rashbaum & Pineiro, Ft. Lauderdale, FL; and
Caroline Ciraolo, Kostelanetz & Fink, Washington, D.C.

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Caroline D. Ciraolo Participates In A Panel Entitled “Ethical Considerations for Former and Current Government Tax Attorneys” For The ABA Section Of Taxation's Virtual Fall Meeting
2021-09-24 13:10 - 14:00
On September 24, 2021, Caroline D. Ciraolo participates in a panel entitled “Ethical Considerations for Former and Current Government Tax Attorneys” for the American Bar Association Section of Taxation’s Virtual Fall Meeting. The meeting is a five-day event led by the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.
Description: This panel examines an attorney’s professional obligations relating to the “revolving door” of entering or leaving the federal government. The discussion focuses on a number of ethical issues for tax attorneys to consider including, among others, conflicts of interest, the duty of loyalty, and the duty of confidentiality. The panelists also cover the post-employment restrictions that impact attorneys looking for or switching to a new job. The panel’s participants are as follows:
Moderator

Michael Desmond, Partner, Gibson, Dunn & Crutcher LLP, Los Angeles, CA

Panelists

Caroline D. Ciraolo, Kostelanetz & Fink, LLP, Washington, DC; and
Kirsten N. Witter, Senior Level Counsel (General Legal Services), IRS Office of Chief Counsel, Washington, DC (Invited)

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Caroline D. Ciraolo And Robert M. Russell Present A Course Entitled “International Tax Controversies” For Georgetown Law Executive Education’s 2021 Saudi Tax Leaders Program
2021-10-04 - 2021-10-05
On October 4 and 5, 2021, Caroline D. Ciraolo and Robert M. Russell present a course entitled “International Tax Controversies” for Georgetown Law Executive Education’s 2021 Saudi Tax Leaders Program.
Description: The inaugural Georgetown Law Executive Education Saudi Tax Leaders Program brings together a stellar group of experts to lead program discussions for attendees, including attorneys and accounting professionals, all of whom work in tax law and policy or tax accounting for the government of the Kingdom of Saudi Arabia. Ms. Ciraolo and Mr. Russell will present two sessions focused on International Tax Controversies, modeled after their annual course offered in the Georgetown University Law Center’s Graduate Tax Program.

Don Fort Jointly Conducts An ACAMS Alabama Chapter Event Entitled "Current IRS Trends Impacting AML Professionals" With Eric Hylton
2021-10-05 13:00 - 14:00
On October 5, 2021, K&F Director of Investigations Don Fort jointly conducts a virtual event for the Alabama Chapter of the Association of Certified Anti-Money Laundering Specialists (ACAMS) entitled “Current IRS Trends Impacting AML Professionals” with ZMFF&J Director of Investigations Eric Hylton.
Description: With a combined 60 years of experience as IRS Senior Executives responsible for both Civil and Criminal enforcement, Don Fort and Eric Hylton discuss current trends and developments at the IRS to include the proposed Infrastructure bill, AMLA 2020, proposed cryptocurrency regulations and the IRS budget. In addition, the presentation includes details of the current state of affairs of data analytics within the IRS and how that impacts AML professionals.
Learn more and register here.

Sharon L. McCarthy Participates In A Panel Entitled “Best Practices or Not? Internal Corporate Investigations” For The Federal Bar Council
2021-10-05 18:00 - 19:30
On October 5, 2021, Sharon L. McCarthy participates in a panel entitled “Best Practices or Not? Internal Corporate Investigations” for the Federal Bar Council. Internal corporate investigations typically result from discovery – by the company, the media, an external auditor, or a whistleblower – of circumstances that raise a serious concern of financial or other misconduct, which may expose the company, management, and the board to civil or criminal liability. The goal of internal investigations is to determine the validity and seriousness of the alleged conduct and what action, if any, the company should take consistent with the best interests of the future of the company and its employees/shareholders.
Description: This program is intended to sensitize practitioners involved in internal investigations to complex, thorny issues that frequently arise, including those relating to: attorney-client privilege; employee interviews and representation concerns; whether to cooperate with government agencies or risk enforcement action and/or criminal prosecution; cross-border issues such as data privacy laws, cultural and language differences, and the specter of both foreign and domestic investigations and litigation. The distinguished panel will share their experiences from multiple perspectives. The panel’s participants are as follows:
Moderator

John J. Kenney, Esq., Hoguet Newman Regal & Kenney, LLP

Panelists

William E. Craco, Esq., Johnson & Johnson;
Laura Grossfield Birger, Esq., U.S. Attorney’s Office, SDNY;
Henry Klehm, III, Esq., Jones Day;
Sharon L. McCarthy, Esq., Kostelanetz & Fink, LLP; and
Hon. Jed S. Rakoff, U.S. District Judge

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Don Fort Participates In A Panel Entitled "How Technology-Enabled Transformation Will Shrink the Tax Gap and Improve Taxpayer Service" At The NAPA Symposium Series On The Transformation Of The IRS
2021-10-19 12:00 - 13:30
On October 19, 2021, K&F Director of Investigations Don Fort participates in a panel entitled “How Technology-Enabled Transformation Will Shrink the Tax Gap and Improve Taxpayer Service” for the National Association of Public Administration’s Symposium Series on the Transformation of the IRS.
This panel focuses on how the IRS can more effectively deploy advanced, but available, technologies such as machine learning to significantly reduce the tax gap by providing top-notch taxpayer service and more effectively finding taxpayers who have not fully reported the taxes that they legally owe. The panel discusses the challenges related to deploying new technologies while simultaneously modernizing the IRS’s very old core accounting systems. This panel, moderated by Dr. Fred Forman, former EVP for American Management Systems and IRS Associate Commissioner for Modernization, explores these issues.
Panelists

Richard Spires, former IRS and DHS Chief Information Officer, former President of Learning Tree International and former President of Palo Alto Systems
David Powner, NAPA Fellow and former GAO Director of IT Management Issues now with MITRE as Executive Director, Center for Data-Driven Policy
Don Fort, Director of Investigations at Kostelanetz & Fink, LLP, and the immediate past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division
Selvi Stanislaus, Executive Officer of the Franchise Tax Board (FTB)

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Megan L. Brackney Participates In A Webinar Entitled "Handling Controversy and Staying Out of Trouble (CLE Ethics)" For The UJA
2021-10-20 12:00 - 12:50
On October 20, 2021, Megan L. Brackney participates in a panel entitled “Handling Controversy and Staying Out of Trouble (CLE Ethics)” for the UJA-Federation of New York. The UJA is hosting the 52nd Annual Sidney Kess New York Estate, Tax & Financial Planning Conference on Tuesday, October 19 and Wednesday, October 20.
The webinar is described as follows:
Tax practice can be categorized into three different stages: tax planning, tax return preparation, and audit/trial representation. Each stage has its own ethical considerations. What differentiates legitimate tax planning from tax evasion? How sure do you have to be before you can tell a client it is okay to take a position on a return? Do you have to audit a client’s records, or can you rely on what the client says? After the return has been filed, how do you handle an audit when you know the client’s tax return is wrong? What do you do if the information you submitted to the IRS is not accurate? This webinar will use real-life examples and provide tips for tax professionals who want to stay out of trouble.
Learning Objectives

Recognize how ethical standards apply to everyday tax practice;
Identify sources of ethical standards and rules that you may not have known about;
Determine standards for advising taxpayers about positions on tax returns;
Differentiate when you can rely on what your client tells you and when you must ask more questions; and
Recall sticky issues that can arise during audits and other controversies.

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K&F And The Morehouse-Spelman Pre-Law Society Host A Program Entitled "Tax Law and Racial Justice"
2021-10-20 19:00 - 20:30
On October 20, 2021, K&F, led by Destiny Reese, co-hosts a program entitled “Tax Law and Racial Justice.” This program is hosted in partnership with the Morehouse-Spelman Pre-Law Society and aims to examine, with students at the historically Black institutions of Spelman College and Morehouse College, the racial biases embedded in the United States tax system. It will also encourage students to consider careers in tax law as opportunities to achieve racial justice.
The program includes a presentation by K&F attorneys Megan L. Brackney, Caroline D. Ciraolo, Daniel Davidson, Zenia Memon, and Robert Russell.
Email Destiny Reese at dreese@kflaw.com to register.

Caroline D. Ciraolo Moderates A Panel Entitled “FBAR Litigation Developments” For STEP USA
2021-10-21 12:00 - 13:30
On October 21, 2021, Caroline D. Ciraolo moderates a panel entitled “FBAR Litigation Developments” for STEP USA.
Description: The IRS and DOJ have been aggressive in pursuing judicial recourse to enforce and seek collection of FBAR assessments. In July of 2020, we presented a Webinar on this topic. Our upcoming Webinar will address the new and key issues and considerations in the litigation of an FBAR case, of which there have been many. The format for the presentation will be an interactive question and answer format among our panelists. There will be an opportunity for attendees to pose questions to our panelists. The panel’s participants are as follows:
Moderator

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP, Washington, DC and Baltimore, MD.

Panelists

James Dawson, Partner, Holland & Knight, West Palm Beach, FL
Jeffrey Neiman, Founding Member, Marcus Neiman Rashbaum & Pineiro LLC, Ft. Lauderdale, FL
Zhanna A. Ziering, Partner, Moore Tax Law Group, New York, NY

Click here for more information and to register.

Caroline D. Ciraolo Presents “The IRS is Focused on Enforcement – What You Need to Know to Navigate Troubled Waters” For The National Association Of State Bar Tax Sections
2021-10-22
On October 22, 2021, Caroline D. Ciraolo presents “The IRS is Focused on Enforcement – What You Need to Know to Navigate Troubled Waters” for the Annual Meeting of the National Association of State Bar Tax Sections in Nashville, TN.
Description: In March 2020, the IRS formed the Office of Fraud Enforcement and appointed a former IRS Criminal Investigation Special Agent in Charge and Director of International Operations to lead its development. Since then, the IRS has appointed a National Fraud Counsel, enhanced fraud training efforts across the IRS operating divisions, reinforced fraud referral procedures with subject matter experts, announced new compliance campaigns, and initiated parallel proceedings targeting taxpayers and professional enablers participating in abusive tax avoidance schemes. In April 2021, the IRS established the Office of Promoter Investigations and appointed as its Acting Director a veteran of the IRS with extensive experience managing investigations and examinations involving abusive transactions. Priority areas include, but are not limited to, micro-captive insurance, syndicated conservation easements, and Puerto Rico residency programs. While these transactions can be the subject of abuse, they are not inherently improper and practitioners need to be prepared to defend reasonable positions. This session discusses the current state of enforcement, recent developments, and what we can expect in the days to come.

Bryan C. Skarlatos Participates In A PLI Panel Entitled "Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know"
2021-10-22 13:15 - 14:15
On October 22, 2021, 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 Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2021” hosted by the Practising Law Institute (PLI).
Description: “Tax Strategies 2021” focuses on the tax issues presented by the entire spectrum of modern major corporate transactions, from single-buyer acquisitions of a division or subsidiary to multi-party joint ventures, cross-border mergers, and complex acquisitions of public companies with domestic and foreign operations, including spin-offs and other dispositions of unwanted operations. In their panel, Kelley C. Miller, Bryan C. Skarlatos, and Sharyn M. Fisk (Invited) discuss ethics rules related to advising clients on corporate transactions, including tax motivated transactions and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit. They also discuss the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Panelists:

Kelley C. Miller, Partner, Reed Smith, LLP
Bryan C. Skarlatos, Partner, Kostelanetz & Fink LLP
Sharyn M. Fisk, Director, Office of Professional Responsibility, Internal Revenue Service

Robert Russell Participates In A Panel Entitled "Go Big and Go Home – Analyzing the Major Business Tax Provisions in Budget Reconciliation" For TEI’s 76th Annual Conference
2021-10-25 09:45 - 10:45
Robert Russell serves as a panelist at TEI’s 76th Annual Conference for the session called “Go Big and Go Home – Analyzing the Major Business Tax Provisions in Budget Reconciliation,” slated for 9:45 a.m.–10:45 a.m. (EDT) on Monday, October 25, 2021.
Description: Much hay has been made of potential business tax reform recently. This panel discusses practical insights to help separate the wheat from the chaff of various proposals.
Click here for more information and to register.

Don Fort Participates In A Panel Entitled “Cryptocurrency Update” For The FBA Section On Taxation
2021-10-26 12:00 - 13:00
*This event has been postponed until a later date. Check back for updates.
On October 26, 2021, K&F Director of Investigations Don Fort participates in a panel entitled “Cryptocurrency Update” for the Federal Bar Association’s Section on Taxation.
The panelists discuss current cases and developments in the field, technology tools and audit streams, the recent John Doe summonses, and Operation Hidden Treasure. In addition, the panelists review important changes to the Infrastructure Investment and Jobs Act, as well as IRS guidance on hard forks and like-kind exchanges.
Panelists:

Don Fort, CPA, Kostelanetz & Fink, LLP
Sarah Paul, Partner, Eversheds Sutherland
Carolyn A. Schenck, National Fraud Counsel and Assistant Division Counsel (International), SB/SE Office of Chief Counsel, Internal Revenue Service

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Caroline D. Ciraolo Presents “When Avoidance Crosses the Line: Criminal Investigation of Abusive Tax Schemes” For The 56th Annual Southern Federal Tax Institute
2021-10-26 14:10 - 15:10
On October 26, 2021, Caroline D. Ciraolo presents “When Avoidance Crosses the Line: Criminal Investigation of Abusive Tax Schemes” for the 56th Annual Southern Federal Tax Institute.
Description: The IRS has ramped up its efforts to combat abusive tax schemes. Enhanced coordination and collaboration is providing IRS personnel with the tools and training to identify promoters, investors, and professional enablers, and to pursue civil examinations, promoter investigations and, where warranted, criminal investigations. Individuals and entities caught in this web are battling on multiple fronts and frequently dealing with government agencies pursuing different objectives and seeking divergent resolutions. This presentation will review the current enforcement landscape with respect to syndicated conservation easements and micro-captive insurance companies, the need to avoid conflicts, best practices for protecting privileges, responding to multiple requests for documents and information, managing public perception, defending criminal allegations, and more.
Click here for more information and to register.

Caroline D. Ciraolo Moderates A Panel Entitled “IRS Undeterred: An Update on Criminal Tax Enforcement” For The American Bar Association’s 36th National Institute On White Collar Crime
2021-10-27 10:30 - 11:45
On October 27, 2021, Caroline D. Ciraolo moderates a panel entitled “IRS Undeterred: An Update on Criminal Tax Enforcement” for the American Bar Association’s 36th National Institute on White Collar Crime.
Description: While the world has been on pause, the IRS Fraud Enforcement Office and IRS Criminal Investigation have not missed a beat. Seasoned tax practitioners and IRS leadership will discuss the latest developments in IRS fraud and criminal tax enforcement, including current priorities, fraud referrals, cross border collaborations, investigative tools being used, and recent prosecutions.
Moderator:
Caroline D. Ciraolo, Kostelanetz & Fink LLP
Panelists:
Nathan J. Hochman, Browne George Ross O’Brien Annaguey & Ellis LLP
Sara G. Neill, Capes Sokol Goodman & Sarachan, P.C.
Jeffrey Neiman, Marcus Neiman Rashbaum & Pineiro LLP
R. Damon Rowe, Executive Director of Fraud Enforcement, IRS
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Caroline D. Ciraolo Facilitates A Discussion With USC Prof. Jeesoo Nam At The Tax Policy Colloquium Speaker Series, Loyola Law School
2021-11-01 15:00 - 17:00
On November 1, 2021, Caroline D. Ciraolo facilitates a discussion with Professor Jeesoo Nam (USC Tax Law) entitled “Tax Justice for Criminal Activities” for LMU Loyola Law School’s Tax Policy Colloquium. The discussion will focus on Professor Nam’s publication of the same name. The discussion’s participants are as follows:
Speaker

Jeesoo Nam, USC School of Law

Commentators

Caroline D. Ciraolo, Kostelanetz & Fink, LLP
William Bunting, Temple University

Click here for more information and to register.

Megan L. Brackney Presents A CLE Program Entitled “Domestic & Financial Abuse: Advising Clients When Facing The IRS” For The NYSBA
2021-11-03 14:00 - 15:30
On November 3, 2021, Megan L. Brackney presents a CLE Program entitled “Domestic & Financial Abuse: Advising Clients When Facing The IRS” for the New York State Bar Association.
Although it is less commonly understood than other forms of intimate partner violence, financial abuse ranks as one of the most powerful methods of keeping a victim trapped in an abusive relationship. Research shows that victims often are reluctant to end an abusive relationship because they are concerned about their financial security or their ability to provide financially for themselves and their children. Financial abuse involves controlling a victim’s ability to acquire, access, and maintain financial resources or other economic safety nets. Victims of this form of abuse may have their education or job opportunities hijacked, be required to hand over their paychecks, and/or be intentionally kept in the dark about finances. In some cases, victims may have their credit destroyed. Others may face frightening tax consequences because of the abuse they endured. Financial abuse, particularly when coupled with other forms of coercive control and emotional, physical, and sexual abuse, is deeply damaging with effects that last long after the toxic relationship has ended.
Attorneys that address financial issues (such as tax, divorce, spousal and child support, bankruptcy, and trust, estate and consumer matters) need to be able to recognize and respond to this form of abuse in their practice.
With a focus on financial abuse and federal income taxes, this program explores:
Part I
• What is financial abuse?
• What are the tactics of abuse?
• Recognize and support domestic violence-involved clients in your legal practice
Part II
The IRS provides detailed procedures for certain individuals who are divorced or legally separated from a spouse to obtain equitable relief from joint liability for tax deficiencies and underpayments with respect to joint tax returns. These individuals (known as “innocent spouses”) may be able to obtain relief if, under all the facts and circumstances, it would be inequitable to hold them responsible for the outstanding tax liability. This section provides an introduction to the Innocent Spouse rules, the process for applying for relief under these rules, how domestic violence may be considered in applications for relief, and the IRS’ current views regarding the relative relevance of different types of abuse.
Speakers

Megan L. Brackney, Esq., Kostelanetz & Fink
Laura Russell, Esq., Legal Aid Society of New York City
Amy Schwartz-Wallace, Esq., Empire Justice Center

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Caroline D. Ciraolo Participates In A Panel Entitled “Tips and Traps (or Hot Topics) in Dealing with International Taxpayers and Reporting”
2021-11-04 16:45 - 18:15
On November 4, 2021, Caroline D. Ciraolo participates in a panel entitled “Tips and Traps (or Hot Topics) in Dealing with International Taxpayers and Reporting.” This panel is part of the 2021 Annual Meeting of the California Tax Bar and California Tax Policy Conference.
Description: We live in a global economy and many of your clients will have sources of income, investments, assets or activities outside the United States. With these often come complex international tax and reporting obligations, the violation of which can result in substantial civil penalties and, in cases involving willful conduct, criminal exposure. With the automatic exchange of information, increased collaboration among treaty partners, and searches driven by data analytics, it is no longer a matter of if the government will find an offshore asset, but when. This diverse panel will review the common international reporting obligations, potential penalties, applicable statutes of limitations, available defenses, and potential paths to compliance, including the latest developments in voluntary disclosures.
Speakers

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

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