Michael Sardar Participates In A Panel Entitled “What Does The IRS Have? How To Make A Freedom Of Information Act (FOIA) Request And Why” At The IRS Representation Conference
2020-11-19 12:30 - 13:30 (America/New_York)
On November 19, 2020, Michael Sardar participates in a panel entitled “What Does the IRS Have? How to Make a Freedom of Information Act (FOIA) Request and Why” as part of the IRS Representation Conference’s Low-Income Taxpayer Clinic Workshop.
Panel information: Maybe the client was audited, has been assessed a trust fund recovery penalty, or is the subject of a criminal investigation after dealing with the IRS Collections Division. There many reasons why it would be really helpful to have a look at what the IRS file says about the taxpayer and their situation. This panel discusses the mechanics of drafting and filing a request under the Freedom of Information Act, including what records are available, what records might be withheld pursuant to various exemptions, and how best to make use of that information to help your taxpayer.
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Caroline D. Ciraolo Participates In A Panel Entitled “Avoiding A Criminal Referral For Employment Tax Violations” At The IRS Representation Conference
2020-11-19 14:45 - 15:45
On November 19, 2020, Caroline D. Ciraolo participates in a panel entitled “Avoiding a Criminal Referral for Employment Tax Violations” as part of the IRS Representation Conference’s Low-Income Taxpayer Clinic Workshop.
Panel information: Statistically, nearly 80% of small businesses fail, often owing payroll taxes. Many of these situations are resolved by the IRS with its civil enforcement tools, but some are referred to IRS Criminal Investigation. So, what makes one case a civil matter and another case ripe for criminal investigation and prosecution? The panel discusses the statutory framework, applicable rules and regulations, and steps employers can take if they find themselves falling behind on their employment tax obligations in an effort to avoid a criminal referral.
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Megan L. Brackney Participates In A Panel Entitled “Partnership Audit Rules” At The NYU 79th Virtual Institute On Federal Taxation
2020-11-19 16:00 - 18:00
On November 19, 2020, Megan L. Brackney participates in a panel entitled “Partnership Audit Rules” as part of the NYU 79th Virtual Institute on Federal Taxation.
Panel information: UPDATE ON THE CENTRALIZED PARTNERSHIP AUDIT RULES: ARE YOU AND YOUR CLIENTS READY? Now that entities taxed as partnerships and their tax advisors have had three years to understand and put into place procedures as well as revisions to outstanding partnership and LLC operating agreements to adapt to the new partnership audit rule regime, the focus now turns to how tax audits, appeals, settlements, litigation, and appeals of adverse judicial determinations will work in “real time.” The co-chairs address problems associated with elections-out, understatement modifications, push-outs and pull-ins, as well as how partners can protect themselves from the partnership representative’s unilateral authority to settle out all partnership issues. Continuing applicability of the TEFRA audit rules for tax years beginning on or before 2017 also are discussed.
Co-Chairs: Jerald David August, Esq., Partner, Fox Rothschild, Philadelphia, PA Megan L. Brackney, Esq., Partner, Kostelanetz & Fink, New York, NY
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Caroline D. Ciraolo Interviews IRS Chief Counsel Michael Desmond During The IRS Enforcement Update Panel At The IRS Representation Conference
2020-11-20 08:40 - 10:40
On November 20, 2020, Caroline D. Ciraolo interviews IRS Chief Counsel Michael Desmond during the IRS Enforcement Update panel at the IRS Representation Conference.
Panel information: Voluntary compliance and enforcement of the tax laws are at the heart of our tax system. Over the past several years, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers report and pay the correct amount of tax. Ms. Ciraolo’s interview provides an update on new developments at the IRS, Office of Chief Counsel.
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Bryan C. Skarlatos Moderates A Panel Entitled “IRS Enforcement Update” At The IRS Representation Conference
2020-11-20 08:40 - 10:40
On November 20, 2020, Bryan C. Skarlatos moderates a panel entitled “IRS Enforcement Update” as part of the IRS Representation Conference.
Panel information: Voluntary compliance and enforcement of the tax laws are at the heart of our tax system. Over the past several years, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers report and pay the correct amount of tax. The panel providea an update on new developments at the IRS.

SB/SE: Eric Hylton, Commissioner, SB/SE Division, Internal Revenue Service, interviewed by Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT
Collections: Eric Hylton, Commissioner, SB/SE Division, Internal Revenue Service, interviewed by Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT
Criminal: James Lee, Chief, Criminal Investigation, Internal Revenue Service, interviewed by Kathy Keneally, Esq. Jones Day, New York, NY
Office of Chief Counsel: Michael Desmond, Chief Counsel, Internal Revenue Service, Washington, DC, interviewed by Caroline D. Ciraolo, Esq. Kostelanetz & Fink, LLP

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Megan L. Brackney Participates In A Panel Entitled “Dealing With The Undocumented Worker” At The IRS Representation Conference
2020-11-20 12:45 - 13:45
On November 20, 2020, Megan L. Brackney participates in a panel entitled “Dealing with the Undocumented Worker” as part of the IRS Representation Conference.
Panel information: Employers who choose to hire undocumented workers often do not understand the potential mess they have created for themselves and their workers. The panel unpacks the myriad issues these employers face, including employment taxes, labor violations, and immigration issues. The panel also discusses potential ways to clean up the situation before IRS initiates contact.
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Sharon L. McCarthy Participates In A Panel Entitled “Defenses To Tax Crimes: Attacking Willfulness” At The IRS Representation Conference
2020-11-20 15:00 - 16:00
On November 20, 2020, Sharon L. McCarthy participates in a panel entitled “Defenses to Tax Crimes: Attacking Willfulness” as part of the IRS Representation Conference.
Panel information: tax crimes are specific intent crimes—requiring the violation of a known legal duty. The panel explores when a potential mental impairment should be considered as a defense or as mitigation in sentencing.
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Bryan C. Skarlatos Participates In A Fireside Chat With The Commissioner Of The IRS, Charles P. Rettig Hosted By The NYU Law Graduate Tax Program
2020-11-23 15:00 - 16:00
On November 23, 2020, Bryan C. Skarlatos LLM ’91 participates in a fireside chat with the Commissioner of the IRS, Charles P. Rettig LLM ’82 hosted by the NYU Law Graduate Tax Program.
Description: This special conversation includes sharing reflections and experiences over a long career and is part of our ongoing virtual celebration of the Graduate Tax Program at 75 years.
Steven Dean, Director of the NYU School of Law Graduate Tax Program introduces the discussion.
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Don Fort Participates In A Panel Entitled "What Every Estate Planner and Tax Advisor Should Know About Criminal Tax and White Collar Crimes?" For The Hawaii State Bar Association
2020-12-01
On December 1, 2020, Don Fort participates in a webinar panel entitled “What Every Estate Planner and Tax Advisor Should Know About Criminal Tax and White Collar Crimes?” hosted by the Hawaii State Bar Association (HSBA).
The presentation addresses the HSBA’s Tax Section, Probate and Estate Planning (PEP) and Elder Law Sections, and International Law Section. Members of the Hawaii Society of CPAs are also invited to attend.
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Michael Sardar Presents “Nobody Is Perfect: How Sure Do You Need to Be When Taking a Position on a Return” At The 22nd Baruch College Estate, Tax, And Finance Planning Conference
2020-12-01 13:00 - 14:00
On December 1, 2020, Michael Sardar presents “Nobody Is Perfect: How Sure Do You Need to Be When Taking a Position on a Return” at the 22nd Baruch College Estate, Tax, and Finance Planning Conference.

Description:
This course covers the tax reporting standards applicable to taxpayers and practitioners and review when penalties can be imposed for tax return errors.

Learning Objectives:
Recognize what standards apply when the IRS determines whether or not to impose a penalty in connection with an erroneous position on a tax return
Demonstrate the difference between the reasonable basis, substantial authority, and more likely than not standards
Identify when can the practitioner be penalized for an error on a taxpayer’s return
Identify when, how, and why to make adequate disclosure of an uncertain tax position
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Megan L. Brackney Teaches A Course Entitled “Tax Penalties: Focus On IRS Enforcement Priorities” For CPA Academy
2020-12-02 11:00 - 12:00
On December 2, 2020, Megan L. Brackney teaches a course entitled “Tax Penalties: Focus on IRS Enforcement Priorities” for CPA Academy.
Course Description: This program will discuss the tax penalties that relate to the IRS’s current enforcement priorities, including trust fund recovery penalties, gross valuation misstatement penalties, and foreign asset reporting penalties.
Learning Objectives:

Recognize several types of tax penalties.
Identify the potential defenses to penalties, including the meaning of “reasonable cause” in these specific contexts.
Demonstrate the procedures for challenging these penalties.

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Robert M. Russell Participates In A Panel Entitled "A Closer Look At Section 965 Campaigns” At D.C. Bar Taxation Community Tax Audits And Litigation Series
2020-12-02 12:00 - 13:30
On December 2, 2020, Robert M. Russell participates in a panel entitled “A Closer Look at Section 965 Campaigns” at D.C. Bar Taxation Community Tax Audits and Litigation Series.
Description: Under the TCJA, Section 965 requires that US shareholders, including individuals, that directly or indirectly own at least 10% of the stock of a specified foreign corporation, include in gross income their share of the corporation’s accumulated deferred foreign income. Panelists will discuss how the IRS is approaching Section 965 compliance through the campaigns, methodologies for calculating and reporting tax under Section 965, privilege issues, and potential penalties for noncompliance.
Speakers:
Robert M. Russell, Kostelanetz & Fink, LLP
Orrin D. Byrd, Director Field Operations East LB&I Cross Border Activities (CBA)
Kathleen Saunders Gregor, Ropes & Gray LLP

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Don Fort Interviewed By Tom Temin On "Federal Drive With Tom Temin"
2020-12-03
On December 3, 2020, Don Fort discussed his new role as Director of Investigations at Kostelanetz & Fink and reflected on his nearly 30 years of experience at the IRS during his interview with Tom Temin.
On “Federal Drive with Tom Temin,” Tom Temin interviews federal executives and government contractors who provide analysis and insight on the many critical issues facing the Executive branch.
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Don Fort Participates In A Panel Entitled “Criminal Tax Update” At UNC School Of Law Tax Institute Speaker Series
2020-12-04 11:00 - 13:30
On December 4, 2020, Don Fort participates in a panel entitled “Criminal Tax Update” at UNC School of Law Tax Institute Speaker Series.
Description: New at UNC Law, the Tax Institute Speaker Series features tax practitioners and scholars from throughout the country who will address current developments in taxation. The Speaker Series offers periodic, short sessions (2-3 hours) with networking opportunities throughout the year.
Program sessions in the first installment of the Speaker Series on December 4, 2020 include:
Criminal Tax Update (11:00am-12:00pm)
Speakers:
Kevin Downing, Kevin Downing Law
Caryn Finley, U.S. Attorney’s Office
Don Fort, Kostelanetz & Fink
Justin Thornton, Law Offices of Justin Thornton
Ethical Issues Under the BBA Partnership Audit Regime (12:30pm-1:30pm)
Speaker:
Christopher S. Rizek, Caplin & Drysdale
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Megan L. Brackney Teaches A Course Entitled “The Nuts and Bolts of Tax Penalties: Analyzing Types of Penalties, Potential Defenses to Penalties, and Procedures for Challenging Penalties” For Lawline
2020-12-07 10:00 - 11:00
On December 7, 2020, Megan L. Brackney teaches a course entitled “The Nuts and Bolts of Tax Penalties: Analyzing Types of Penalties, Potential Defenses to Penalties, and Procedures for Challenging Penalties” For Lawline.
Course description: This program discusses tax penalties assessed against taxpayers, defenses to penalties, and the procedures for challenging penalties. The course discusses common penalties, such as failure to file and failure to pay, accuracy, and fraud penalties, as well as other penalties that the IRS is using more frequently as part of enforcement initiatives, such as trust fund recovery penalties and penalties for failure to report foreign assets.
Learning Objectives:

Gain an understanding of several types of tax penalties that apply to taxpayers
Identify the potential defenses to penalties, including the meaning of “reasonable causes”
Review the procedures for challenging penalties

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Caroline D. Ciraolo Participates In A Panel Entitled “Privileges And Penalties – Maximizing Your Protections And Minimizing Your Regrets” At USA Branch Of The International Fiscal Association International Tax Conference
2020-12-18 11:00 - 12:00
On December 18, 2020, Caroline D. Ciraolo participates in a panel entitled “Privileges and Penalties – Maximizing Your Protections and Minimizing Your Regrets” at USA Branch of the International Fiscal Association International Tax Conference.
Description: This panel addresses hot issues and current developments in privileges and penalties. Using the ongoing Sanmina controversy as a springboard the panel illustrates through realistic fact patterns what we know and don’t know about when various privileges attach in the first instance, how taxpayers can share privileged communications with those who need to know (preparers, valuation experts, accountants, counterparties, the IRS), how to avoid having a selective disclosure become a subject matter waiver, and how to avoid other pitfalls and bad consequences.
Chair: Diana Wollman, Cleary, Gottlieb
Panelists:
Caroline Ciraolo, Kostelanetz & Fink
Erin Gladney, Baker McKenzie
Amanda Leon, Caplin & Drysdale
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Megan L. Brackney Participates In A Panel Entitled “Representing The Promoter – Fighting On Multiple Fronts” At The ABA Virtual 2021 Midyear Tax Meeting
2021-01-27 14:30 - 16:00
On January 27, 2021, Megan L. Brackney participates in a panel entitled “Representing the Promoter – Fighting on Multiple Fronts” at the ABA Virtual 2021 Midyear Tax Meeting.
Description: The IRS has ramped up its efforts to combat abusive or potentially abusive tax schemes. Enhanced coordination and collaboration is providing IRS personnel with the tools and training to identify potential promoters and refer those matters to the Lead Development Center for further case development and, if warranted, authorization of a promoter investigation under IRC 6700 or 6701. Matters may also be referred simultaneously to the Tax Division for civil injunctive action and/or to IRS-Criminal Investigation. In the midst of these parallel proceedings, promoters may find themselves the subject of invasive Congressional inquiries. 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. Our expert panelists will discuss navigating these dangerous waters, avoiding conflicts, best practices for protecting privileges, responding to multiple requests for documents and information, managing public perception, challenging civil penalties, defending criminal allegations, and more.
Panelists:
Megan L. Brackney, Kostelanetz & Fink, LLP
Jenny Johnson Ware, McDermott Will & Emery, LLP
Brendan O’Dell, IRS Promoter Investigations Coordinator
Nanette Davis, Senior Litigation Counsel, Tax Division, US Department of Justice
Carolyn Schenck, National Fraud Counsel, Office of Chief Counsel, Internal Revenue Service

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Caroline D. Ciraolo Chairs The Civil And Criminal Tax Penalties Committee's Programming At The ABA Virtual 2021 Midyear Tax Meeting
2021-01-27 14:30 - 16:00
On January 27, 2021, Caroline D. Ciraolo chairs the Civil and Criminal Tax Penalties Committee’s Programming at the ABA Virtual 2021 Midyear Tax Meeting. The Civil and Criminal Tax Penalties Committee will present a panel entitled “Representing the Promoter—Fighting on Multiple Fronts,” in which Kostelanetz & Fink partner, Megan L. Brackney, will participate.
Chair: Caroline D. Ciraolo, Kostelanetz & Fink LLP
Vice Chairs:
Jenny Johnson Ware, McDermott, Will & Emery LLP
Michael A. Villa Jr., Meadows Collier Reed Cousins Crouch & Ungerman LLP
Brian C. McManus, Latham & Watkins LLP

The ABA’s Virtual 2021 Midyear Tax Meeting consists of more than 40 CLE programs and two plenary sessions over four days. Participants learn from and meet with the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.

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Robert M. Russell Participates In A Panel Entitled “In The News: Recent IRS Compliance Campaigns And How The IRS Is Doing More With Less” At The ABA Virtual 2021 Midyear Tax Meeting
2021-01-27 16:30 - 17:15
On January 27, 2021, Robert M. Russell participates in a panel entitled “In the News: Recent IRS Compliance Campaigns and How the IRS is Doing More with Less” at the ABA Virtual 2021 Midyear Tax Meeting.
Description: Voluntary tax compliance is a bedrock of the U.S. tax system, yet the IRS estimates there is almost a half-trillion annual gap between the taxes that taxpayers legally owe and the amount collected. Reductions in budgets and overall staff may have exacerbated this problem. Using data analytics and employee submissions, the IRS has identified multiple areas that pose significant compliance challenges and instituted campaigns to address these areas. This panel will provide a general overview of (a) campaigns and the Campaign Development Process, and (b) how campaigns may affect a practitioner’s current and future clients.
Moderator: Scott Woody, Gallagher & Kennedy, P.C.
Panelists:
Robert M. Russell, Kostelanetz & Fink, LLP
Amanda Leon, Caplin & Drysdale, Chartered
Mark Nyman, Acting Director of Compliance Planning and Analytics, LB&I- Assistant Deputy Commissioner Compliance Integration (ADCCI), Internal Revenue Service

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Lawrence A. Sannicandro Chairs The Tax Collection, Bankruptcy, And Workouts Committee’s Programming At The ABA Virtual 2021 Midyear Tax Meeting
2021-01-28 14:30 - 16:00
On January 28, 2021, Lawrence (Larry) A. Sannicandro chairs the Tax Collection, Bankruptcy, and Workouts Committee’s programming at the ABA Virtual 2021 Midyear Tax Meeting. The ABA Virtual 2021 Midyear Tax Meeting consists of more than 40 CLE programs and two plenary sessions over four days. Participants learn from and meet with the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.

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Olivia H. Renensland Moderates And Sharon L. McCarthy Participates In A Panel Entitled “Ethical Considerations When Publicly Advocating For A Client” At The ABA Virtual 2021 Midyear Tax Meeting
2021-01-29 13:10 - 14:00
On January 29, 2021, Olivia H. Renensland moderates and Sharon L. McCarthy participates in a panel entitled “Ethical Considerations when Publicly Advocating for a Client” at the ABA Virtual 2021 Midyear Tax Meeting.
Description: Today’s twenty-four hour news cycle provides ample opportunities for presenting a case to the press. This panel will explore the ethical obligations tax lawyers have when making public statements about clients, cases, and opinions of outcomes.
Moderator: Olivia H. Renensland, Kostelanetz & Fink, LLP
Panelists:
Sharon L. McCarthy, Kostelanetz & Fink, LLP
Christopher Rizek, Caplin & Drysdale, Chartered
Greg Andres, Davis Polk

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Sharon L. McCarthy Presents A Webinar Entitled "Ethical Considerations For Tax Pros: Recognizing Conflicts And Asking For Advice" Through CPAacademy.org
2021-01-30
In this webinar, attendees review the duties of a tax professional in advising clients on tax return preparation and audits. Using real-life examples, we identify potential conflicts and other problems that may arise in the course of a tax professional’s representation, as well as discuss recommended methods for addressing them. Among the topics covered area tax professional’s duty of candor to the IRS and the potential for discipline and, in extreme circumstances, criminal prosecution for failure to comply with one’s duties.
For more information, please click here.

Tax Rep Network Podcast Interviews Sharon McCarthy On Mental Defenses to Tax Crimes
2021-02-05
Tax crimes are specific intent crimes – requiring the violation of a known legal duty. Sharon L. McCarthy joins Eric Green of Green & Sklarz LLC and Tax Rep LLC for this week’s Tax Rep Network podcast. Among other topics, Sharon and Eric discuss the requirements for tax offenses and when a potential mental impairment should be considered as a defense or as a mitigating factor in sentencing.
Click here for the Tax Rep Network Podcast – Episode 92 – Was Your Client Really Willful? Mental Defenses to Tax Crimes with Sharon McCarthy. The episode is also available for streaming in most podcast apps (iTunes, Spotify, Apple Podcasts, etc.).

New York City Bar, Personal Income Taxation Committee Hosts Fireside Chat with Charles P. Rettig, Commissioner of Internal Revenue
2021-02-17 18:30 - 19:30
On February 17, 2021 at 6:30 pm, the New York City Bar, Personal Income Taxation Committee, of which associate Stephen Josey is a member, hosts a Fireside Chat with Charles P. Rettig, Commissioner of Internal Revenue. As the Commissioner, Mr. Rettig presides over an agency of about 80,000 employees and a budget of more than $11 billion. He is responsible for the nation’s tax system, which collects more than $3.5 trillion in tax revenue each year representing about 96% of the total gross receipts of the United States. Commissioner Rettig will provide valuable insights for lawyers and other tax practitioners. The Fireside Chat is free for NYC Bar members and non-lawyers.
Interviewer: Frank Agostino, Founder and President, Agostino & Associates P.C.
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Megan Brackney Participates In A Panel Entitled "2020 Planning Rush is Over – Now What?" For STEP NY
2021-02-25 12:00 - 13:00
On February 25, 2021, Megan L. Brackney participates in a panel entitled “2020 Planning Rush is Over – Now What? Gift Tax Returns, Preparing for Audit, and Ensuring the Plan Survives” for STEP NY.
Description:
Most practitioners sprinted to the end of 2020, as many clients sought to make year-end gifts before Dec 31. Now that the dust has settled and we are in a new year – what should practitioners be thinking about now?
Gift tax returns – best practices, technical considerations, ensuring proper filing.
Preparing for IRS audit, should that come up – hear from a tax controversy expert on what to be thinking about now, in case 2020 planning is challenged.
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Don Fort Participates In A Panel Entitled "I’m Getting Rich on Bitcoin" For AML RightSource
2021-02-25 13:00 - 14:00
On February 25, 2021, Don Fort participates in a panel entitled “I’m Getting Rich on Bitcoin” as part of AML RightSource’s monthly webinar series.
Description: The continuing expansion of virtual currencies adoption and the need for financial service providers to understand how to identify cryptocurrency transaction and how to manage its potential risk is increasing. Is your financial institution ready to manage a new virtual economy?
In this webinar, you’ll learn:
(1) the elements of virtual currency transactions,
(2) how your FI is exposed to them (even if you don’t provide services to crypto exchanges), and
(3) how to manage the risk this type of payment method presents.
Moderator: Chuck Taylor, Executive Vice President; AML RightSource
Panelists:
Don Fort, Director of Investigations; Kostelanetz & Fink, LLP
Stephen Ryan, Chief Operating Officer; CipherTrace

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Don Fort and Larry Sannicandro Participate In A Panel Entitled "Cryptocurrency: Current Tax and Bank Secrecy Act Enforcement Environment" For Celesq
2021-02-26
On February 26, 2021, Don Fort and Lawrence Sannicandro participate in a panel entitled “Cryptocurrency: Current Tax and Bank Secrecy Act Enforcement Environment” for Celesq AttorneysEd Center
Description:

Virtual currencies, including cryptocurrency, have recently received significant attention from the IRS, the Financial Crimes Enforcement Network, the U.S. Department of Justice Tax Division, and other law enforcement agencies. The panelists, led by the former chief of the IRS Criminal Investigation Division, will explore recent guidance from FinCEN and/or the IRS with respect to: (1) the collection, retention, and disclosure to the U.S. government of certain transactions involving cryptocurrency; (2) the taxation of, and tax reporting standards for, cryptocurrency; and (3) Bank Secrecy Act reporting, such as the Foreign Bank Account Report. The panelists will also discuss strategies to mitigate the risk of civil and criminal penalties for noncompliance with the internal revenue laws, including the availability of the qualified amended return and the IRS’s voluntary disclosure practice. This webinar is a must-attend for all professionals and practitioners who operate in the space of, or advise on, cryptocurrency.
Learning Objectives:
After this presentation, attendees should understand:
1. Proposed regulations adopting recordkeeping, verification and reporting requirements for certain deposits, withdrawals, exchanges, payments, or transfers of cryptocurrency by, through, or to a bank or money service business;
2. Proposed regulations requiring banks and nonbank financial institutions to collect, retain, and transmit to the U.S. government certain information related to fund transfers and transmittals of funds over $250;
3. The taxation of, and tax reporting standards for, cryptocurrency, including proposed rules requiring cryptocurrency to be reported on FinCEN Form 114, Report of Foreign Bank and Financial Accounts; and
The current civil and criminal regulatory environment, including the use of the qualified amended return and the voluntary disclosure as a means to limit civil and criminal penalties.

Speakers:
Don Fort, Director of Investigations, Kostelanetz & Fink, LLP
Lawrence Sannicandro, Partner, Kostelanetz & Fink, LLP
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Michael Sardar Participates In A Panel Entitled "Keep It Between Us: Recent Developments in Attorney/Client and Tax Practitioner Privileges and Work Product Protections in Tax Cases" At The FBA Tax Conference
2021-03-04 13:00 - 14:00
On March 4, 2021, Michael Sardar participates in a panel entitled “Keep it Between Us: Recent Developments in Attorney/Client and Tax Practitioner Privileges and Work Product Protections in Tax Cases” at the FBA Tax Conference.
Description: As lawyers and tax practitioners, when we correspond with our clients, or prepare for a case, we assume those documents will be protected from disclosure. However, recent tax cases remind us that it is important to pay attention to the elements of each privilege and protection, and to be careful about waiver. This panel will explore the crime/fraud and tax shelter exceptions, the definition of discoverable “tax work papers,” disclosure without subject matter waiver, and other issues raised by these recent cases and developing trends in enforcement.
Learning Objectives:
• Reviewing elements of the privileges and protections that provide protection against disclosure.
• Analyzing recent cases that have explored the limits of these privileges and protections.
• Analyzing whether disclosure will necessarily mean waiver of protections.
Moderator: S. Starling Marshall, Partner, Crowell & Moring LLP
Panelists:

Michael Sardar, Partner; Kostelanetz & Fink, LLP, Private Sector Representative

Brittany L. Harrison, Attorney, Office of Chief Counsel (P&A), IRS
Cory Johnson, Senior Litigation Counsel, Tax Division, U.S. Department of Justice Representative
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Caroline Ciraolo Co-Chairs The FBA Tax Conference 2021 Enforcement & Criminal Tax Symposium
2021-03-05 10:00 - 17:00
Caroline Ciraolo Co-Chairs The 45th FBA Tax Conference 2021 Enforcement & Criminal Tax Symposium on March 3-5, 2021.
Description:
This newly formatted three-day virtual program will offer the same great content online. Examine important tax developments and emerging policy issues in over 30 educational sessions featuring notable speakers from the Internal Revenue Service, Treasury Department, Department of Justice, White House, and Congress. Programming will include a keynote address and awards presentations for both the Annual Writing Competition and prestigious Kenneth H. Liles Award for Distinguished Service to an eminent tax practitioner.
Co-Chairs:
Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Edward Froelich, Of Counsel, Morrison & Foerster
Richard T. Lunger, Division Counsel (Criminal Tax), Office of Chief Counsel, IRS
Steven Toscher, Principal, Hochman Salkin Toscher & Perez, P.C.
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Michael Sardar Participates In A Panel Entitled "Virtual Proceedings in the Digital Age (Part 2): Litigation in District and Appellate Courts" At The FBA Tax Conference
2021-03-05 11:30 - 12:30
On March 5, 2021, Michael Sardar participates in a panel entitled “Virtual Proceedings in the Digital Age (Part 2): Litigation in District and Appellate Courts” at the FBA Tax Conference.
Description: This panel will discuss practice tips and techniques for navigating virtual proceedings, including remote depositions, oral arguments, and trials in both criminal and civil cases. The panelists will discuss the different approaches taken by courts across the United States. Lastly, the panelists will discuss their predictions regarding which of these new procedures may be here to stay post COVID-19.
Learning Objectives:
• Identify various changes and challenges to conducting remote proceedings.
• Depositions: how to deal with objections and instructions for witnesses.
• Depositions: how to deal with exhibits.
• Tips for cross examining witnesses and presenting exhibits at trial.
• Tips for persuasive presentations at oral arguments, hearings, and sentencing.
• Various types of technology used by courts.
Panelists:
Michael Sardar, Partner; Kostelanetz & Fink, LLP
Phillip Colasanto, Associate, Agostino & Associates P.C.
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