Michael Sardar Presents A Webinar Titled “Using the Voluntary Disclosure Process to Bring Taxpayers Back into Compliance" For The CPA Academy
2023-05-02 09:00 - 10:00 (America/New_York)
On May 2, 2023, Michael Sardar presents a webinar entitled “Using the Voluntary Disclosure Process to Bring Taxpayers Back into Compliance” for the CPA Academy. CPE and CE credit is offered for this event.
Description: The IRS’s voluntary disclosure practice provides taxpayers who have previously not complied with their tax and reporting obligations with a pathway back to compliance. The IRS’s voluntary disclosure practice is available to taxpayers whose non-compliance was willful, fraudulent, or even criminal. Under the IRS’s voluntary disclosure practice, taxpayers can avoid criminal prosecution and minimize otherwise applicable civil penalties.
Learning Objectives:

Determine when a voluntary disclosure is appropriate
Classify who is eligible to make a voluntary disclosure
Outline the mechanics of applying for and completing the voluntary disclosure process
Identify the penalty framework applicable under the current IRS voluntary disclosure practice

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Megan L. Brackney Participates In A Panel Titled “Hot Button Topics with the IRS: A Conversation with Three Tax Controversy Practitioners" For STEP NY
2023-05-03 16:00 - 19:00 (America/New_York)
On May 3, 2023, Megan L. Brackney participates in a panel titled “Hot Button Topics with the IRS: A Conversation with Three Tax Controversy Practitioners” for STEP NY.
Description: In this panel, Lawrence Lipoff leads a conversation with Megan L. Brackney, Thomas Ostrander and Miri Forster, three tax controversy experts, about what planners need to know about the IRS’ current cross-border and private client campaigns, programs and issues.

Panelists:

Lawrence Lipoff, CohnReznick LLP (Moderator)
Megan L. Brackney, Kostelanetz LLP
Thomas Ostrander, Duane Morris LLP
Miri Forster, Eisner Advisory Group LLC

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Garrett L. Brodeur Participates In A Panel Titled "Will Robots Replace Lawyers? The Ethics of Lawyers Using ChatGPT" At The ABA 2023 May Tax Meeting
2023-05-05 13:00 - 14:00 (America/New_York)
Garrett L. Brodeur participates in a panel titled “Will Robots Replace Lawyers? The Ethics of Lawyers Using ChatGPT” at the American Bar Association’s 2023 May Tax Meeting in Washington, D.C. on May 5, 2023. Ethics CLE credit is offered for this event.
Description:
The panel discusses the ethics surrounding the use of the ChatGPT chatbot in a legal context. In November 2022, OpenAI launched ChatGPT, an interactive chat robot that uses artificial intelligence to answer questions about anything. While ChatGPT may be able to draft anything from a routine legal document to a complex analysis of a Supreme Court case, lawyers will have to carefully consider how to use this new technology while still upholding their ethical obligations to clients.
Learning Objectives:

Learn about how using ChatGPT implicates the ABA Model Rules of Professional Conduct, including Rules 1.1 (Competence) and 1.6 (Confidentiality)
Learn about privilege considerations when using AI
Learn about potential ethical uses of AI, including creating marketing materials and drafting legal articles.

Moderator:

Carina Federico, Partner, Crowell & Moring LLP

Panelists:

Garrett L. Brodeur, Associate, Kostelanetz LLP
Caitlin Tharp, Associate, Steptoe & Johnson LLP
Andrew Allen, Associate, Morgan Lewis LLP
Ken Crutchfield, VP and General Manager of Legal Markets, Wolters Kluwer Legal & Regulatory (invited)

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Caroline D. Ciraolo Participates In A Panel Titled "Diversity, Equity, and Inclusion in the Workplace and the Impact of Implicit Bias: A Survey of Initiatives and Best Practices in the Legal Profession" At The ABA 2023 May Tax Meeting
2023-05-05 13:25 - 14:45 (America/New_York)
Caroline D. Ciraolo participates in a panel titled “Diversity, Equity, and Inclusion in the Workplace and the Impact of Implicit Bias: A Survey of Initiatives and Best Practices in the Legal Profession” at the American Bar Association’s 2023 May Tax Meeting in Washington, D.C., on May 5, 2023. This panel is hosted by the ABA Section of Taxation’s Diversity Committee and is co-sponsored by the LGBTQ+ Lawyers in Tax Forum. CLE credit is expected to be offered for this event.
Description:
The Diversity Committee continues the discussion it began in San Diego. The importance of diversity, equity, and inclusion (DEI) has gained greater recognition in the workplace and many law firms and organizations have recently implemented new policies and initiatives. As we strive to diversify the legal profession, we need to recognize and address our implicit biases that create roadblocks to these efforts. This panel facilitates a discussion of common implicit biases, the impact they have on the legal profession, and current initiatives and best practices that attendees can apply to their own workplace.
Learning Objectives:

Understand the benefits of maintaining successful DEI initiatives
Identify and remove impediments to improve DEI initiatives in the legal profession
Enable participants to implement changes to their current programs to achieve their DEI goals

Moderator:

Catherine Sullivan, IRS Office of Chief Counsel (SBSE)

Panelists:

Caroline D. Ciraolo, Kostelanetz LLP
Adam Strait, Department of Justice, Tax Division
David Farhat, Skadden, Arps, Slate, Meagher & Flom LLP
Grace Chang, Deloitte Tax LLP
Jessica Harris, Legal Services of Northern Virginia

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William Greco Participates In A Panel Titled "Are You on Record? Don’t Fall Trap to the Record Rule" At The ABA 2023 May Tax Meeting
2023-05-05 16:55 - 17:45 (America/New_York)
William Greco participates in a panel titled “Are You on Record? Don’t Fall Trap to the Record Rule” at the American Bar Association’s 2023 May Tax Meeting in Washington, D.C., on May 5, 2023. This panel is hosted by the ABA’s Tax Collection, Bankruptcy & Workouts Committee and is co-sponsored by the Pro Bono and Tax Clinics Committee. CLE credit is offered for this event.
Description:
The “record rule” is a crucial aspect of tax collection work. In many contexts, including in Collection Due Process hearings and innocent spouse submissions, the “record rule” may limit the evidence that is admissible in a Tax Court case to the administrative record. This panel discusses the history of the record rule, its current application in tax collection matters, and advice on how to make and preserve a complete and adequate record for purposes of Tax Court review. Additionally, the panelists discuss the challenges that taxpayers face in presenting evidence that is outside the scope of the administrative record, as well as strategies for navigating these challenges.
Learning Objectives:

Learn how to build a complete record at the administrative level
Understand the difference between supplementing and completing the administrative record, and how to affect
each
Understand the arguments for and against the Tax Court’s standard for evaluating whether evidence is “newly
discovered or previously-unavailable”
Learn how to identify and meet the challenges of presenting evidence that is outside the scope of the administrative record.

Moderator:

Jonathan Amitrano, Taylor Nelson Amitrano LLP

Panelists:

William Greco, Kostelanetz LLP
Professor Bryan Camp, Texas Tech University
Christine Speidel, Associate Professor of Law & Director of the Federal Tax Clinic, Villanova University

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Sharon L. McCarthy Participates In A Panel Titled "How to Navigate Defending PPP, EIDL and ERC Cases" At The ABA 2023 May Tax Meeting
2023-05-06 10:30 - 11:30 (America/New_York)
Sharon L. McCarthy participates in a panel titled “How to Navigate Defending PPP, EIDL and ERC Cases” at the American Bar Association’s 2023 May Tax Meeting in Washington, D.C. on May 6, 2023.
Description:
The Paycheck Protection Program and Economic Injury Disaster Loan programs were designed to push money out to those who needed it the most, right away. Similarly, the Employee Retention Credit was designed to provide a financial lifeline to certain businesses. Now that the dust has settled, the IRS, the FDIC, and the DOJ are working together to prosecute those suspected of abusing the programs. This panel offers an in-depth analysis of how these cases are referred to the IRS and FDIC, how they are investigated, how they are charged, and strategies for defending them.
Learning Objectives:

Understand how and why the government is investigating and prosecuting abuse of the relief programs.
Identify indicators that trigger audits, fraud examinations and criminal cases.
Develop strategies for defending clients suspected of abusing the relief programs with a focus on mitigating factors.

Moderator:

Damon Rowe, Partner, Meadows Collier Reed Cousins Crouch & Ungerman LLP

Panelists:

Sharon L. McCarthy, Partner, Kostelanetz LLP
Eric Hylton, Director of Investigations, Zerbe, Miller, Fingeret, Frank & Jadav, LLP
Kathy Enstrom, Director of Investigations, Moore Tax Law Group, LLC

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Megan L. Brackney Presents On A Panel Entitled “New Partnership Audit Rules" For The Practicing Law Institute
2023-05-11 08:30 - 09:30 (America/New_York)
On May 11, 2023, Megan L. Brackney presents on a panel entitled, “New Partnership Audit Rules” for the Practicing Law Institute’s “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2023” program.
Description: The BBA audit rules provide a radically different approach for how adjustments are made in the partnership context. Although the BBA was enacted in 2015, practitioners are still grappling with its implications and how to advise clients. This panel will address issues that are critical in transactions and audits, and will discuss the newly issued final regulations. After completing this session, participants will be able to:

Draft provisions in partnership agreements and other transactional documentation that address BBA issues
Calculate the imputed underpayment and evaluate strategies for shifting risk
Address the partnership audit rules in transactional due diligence

Panelists:

Megan L. Brackney, Kostelanetz LLP
Kate Kraus, Allen Matkins Leck Gamble Mallory & Natsis
Jennifer M. Black, Senior Counsel, Office of the Associate Chief Counsel, Internal Revenue Service

CLE credit may be offered for attendance.
Click here for more information and to register.

Megan L. Brackney Presents On A Panel Entitled “Balancing Tax Planning, Advocacy, And Professional Ethics: The Rules That Every Partnership Tax Advisor Should Know" For The Practicing Law Institute
2023-05-11 16:15 - 17:15 (America/New_York)
On May 11, 2023, Megan L. Brackney presents on a panel entitled, “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Partnership Tax Advisor Should Know” for the Practicing Law Institute’s “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2023” program.
Description: This panel will focus on the various judicial doctrines and ethical issues that arise in the partnership tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on transactions involving partnerships and other passthrough entities including standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct
Avoid the ethical pitfalls that arise when providing tax opinions and recommending return positions
Respond to the IRS in an audit

Panelists:

Megan L. Brackney, Kostelanetz LLP
Michael J. Desmond, Gibson, Dunn & Crutcher LLP

CLE credit may be offered for attendance.
Click here for more information and to register.

An Evening With U.S. Tax Court Judge Christian Weiler, Presented By The FBA Section On Taxation And Kostelanetz LLP
2023-05-16 18:00 - 20:00 (America/New_York) | Kostelanetz LLP, Seven World Trade Center, 250 Greenwich Street, 34th Floor, New York, NY, 10007, United States
On May 16, 2023, the Federal Bar Association Section on Taxation will host United States Tax Court Judge Christian N. Weiler for an evening to socialize with the New York tax community. The event is free, courtesy of the FBA Section on Taxation and Kostelanetz LLP.
Reception includes hors d’oeuvres, beer, and wine at the Kostelanetz LLP New York City office.
Please complete the RSVP form below to stay up-to-date on event logistics and firm news.

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Caroline D. Ciraolo Leads A Discussion Titled "You’ve Got a Friend - Leveraging Relationships with Treaty Partners…" At The Cambridge Forum On International Tax & Disputes
2023-05-24 - 2023-05-26
Caroline D. Ciraolo leads a discussion titled “You’ve Got a Friend – Leveraging Relationships with Treaty Partners…” at the Forum on International Tax & Disputes presented by Cambridge Forums.
Description:
Faced with substantial tax gaps, aggressive tax avoidance, and abusive tax structures, tax authorities around the world are increasing civil and criminal tax enforcement efforts. These efforts include the exchange of information, informal collaboration, and formal joint audits and investigations with foreign treaty partners. This session will discuss the scope of EOI provisions in tax treaties and other bilateral agreements, standards of review and defenses to such requests, procedures for cross-border audits and investigations, and possible paths to resolutions.
Speakers:

Caroline D. Ciraolo, Kostelanetz LLP
Christopher Slade, Aird & Berlis LLP

Caroline D. Ciraolo Co-Chairs The Cambridge Forum On International Tax & Disputes
2023-05-24 - 2023-05-26
Caroline D. Ciraolo co-chairs the Cambridge Forum on International Tax & Disputes in Cascais, Portugal.
Description:
The Forum Steering Committee welcomes up to 40 leading lawyers personally selected from renowned regional, national, and multinational firms around the world. With increased transparency and information sharing amongst tax authorities, the use of aggressive techniques like criminal investigations and digital taxation, and pandemic related mobility issues on the rise, the Forum provides an opportunity to keep abreast of developments in key jurisdictions around the world.
Using candid, seminar-style discussion, the group shares experiences and engages in meaningful dialogue on the most pressing issues they face.
2023 Forum Steering Committee Co-Chairs:

Caroline D. Ciraolo, Kostelanetz LLP, Washington, D.C.
Susanne Schreiber, Bär & Karrer, Zürich, Switzerland

2023 Forum Steering Committee Members:

Alexandra Courela, Abreu Advogados, Lisbon, Portugal
Dr. Hardy Fischer, POELLATH, Berlin, Germany
Denise Honey, Pitcher Partners Ltd., Melbourne, Australia
Parul Jain, Nishith Desai Associates, New Delhi, India
Victor A. Jaramillo, Caplin & Drysdale, Washington, D.C.
Alex Jupp, Skadden, Arps, Slate, Meagher & Flom LLP, London, United Kingdom
Christian Wimpissinger, BINDER GRÖSSWANG, Vienna, Austria

Click here for more information.

Don Fort Participates In The Cambridge Forum On International Tax & Disputes
2023-05-24 - 2023-05-26
Don Fort participates in the Cambridge Forum on International Tax & Disputes in Cascais, Portugal.
Description:
The Forum Steering Committee welcomes up to 40 leading lawyers personally selected from renowned regional, national, and multinational firms around the world. With increased transparency and information sharing amongst tax authorities, the use of aggressive techniques like criminal investigations and digital taxation, and pandemic related mobility issues on the rise, the Forum provides an opportunity to keep abreast of developments in key jurisdictions around the world.
Using candid, seminar-style discussion, the group shares experiences and engages in meaningful dialogue on the most pressing issues they face.
Click here for more information.

Heather Fincher Presents On A Panel Entitled "What to do when Advisors Find Errors in International Tax Returns" At The Procopio International Tax Institute 2023 International Update: U.S. – Mexico Cross-Border Tax Issues
2023-05-25 10:30 - 11:30 (America/Los_Angeles)
On May 25, 2023, Heather Fincher presents on a panel entitled, “What to do when Advisors Find Errors in International Tax Returns” at the Procopio International Tax Institute 2023 International Update: U.S. – Mexico Cross-Border Tax Issues.
Description:
Heather is moderating an engaging discussion of real-life hypos, common mistakes, and practical takeaways for handling errors and helping clients come into compliance with international filing obligations.
Moderator:

Heather Fincher, Kostelanetz LLP

Panelists:

Daniel N. Price, Law Office of Daniel N. Price PLLC
Torakichi Jesús Oba Perez, T. Jesus Oba Perez, EA, CPA
Robert Russell, Rutan & Tucker LLP

Click here for more information and to register.

Don Fort Presents On The AML Rightsource Voices Webinar Titled “Private-Public Partnerships and how they enhance detection, prevention, and reporting of financial crime”
2023-05-25 13:00 - 14:00 (America/New_York)
On May 25, 2023, Don Fort presents on the AML Rightsource Voices Webinar titled “Private-Public Partnerships and how they enhance detection, prevention, and reporting of financial crime.”
Description:
The AML/Sanctions/CFT community has long embraced partnerships and collaboration. This edition of AML Voices will focus on the value of these partnerships and spotlights a tremendous example – the recent Global Financial Institutions Summit (GFIS) on tax crime.
Moderator:

John Byrne, AML Rightsource Advisory Board

Presenters:

Don Fort, Kostelanetz LLP
Marilu Jimenez, FINCAdvisors
Tom Fattarusso, IRS-Criminal Investigation

Click here for more information and to register.

Don Fort Appears On Tax Chat! Series On Transforming Tax Administration Entitled "Tax Chat on Big Data and AI in Tax Administration" At The Center For Taxpayer Rights
2023-05-30 12:00 - 13:00 (America/New_York)
On May 30, 2023, Don Fort appears on the Center for Taxpayer Rights’ Tax Chat! Series on Transforming Tax Administration in an episode entitled “Tax Chat on Big Data and AI in Tax Administration.”
Participants:

Host: Nina Olsen, former National Taxpayer Advocate
Guest: Don Fort, Kostelanetz LLP

Click here for more information and to register.

Andrew Weiner Presents On A Panel Titled “Key Developments in Tax Controversy” At The FBA Insurance Tax Conference
2023-06-01 16:30 - 17:30 (America/New_York)
On June 1, 2023, Andrew Weiner presents on a panel titled “Key Developments in Tax Controversy” at the FBA Insurance Tax Conference.
Description:
This panel will cover several recent, critical developments in the tax controversy space. The program will provide the attendees with an understanding of the Inflation Reduction Act funding for the Internal Revenue Service and the impact of that funding on IRS enforcement. It will address the important new guidance in Revenue Procedure 2022-39 (exam procedures for large businesses under continuous audit), key changes to Schedule UTP (disclosing uncertain tax positions), and the potential impact of In re Grand Jury. Participants will also learn about notable outcomes and ongoing litigation involving Administrative Procedure Act challenges in the tax context.
Moderator:

Sharon Katz-Pearlman, Shareholder, Greenberg Traurig LLP

Panelists:

Andrew Weiner, Kostelanetz LLP
Mary Slonina, Managing Director, KPMG LLP
Caitlin Tharp, Associate, Steptoe & Johnson LLP

Click here for more information and to register.

Jay Nanavati Moderates A Panel Titled "Puerto Rico's Act 20/22 Tax Incentive Program: Residency And Sourcing Under The IRS's Microscope" At The 2023 NYU Tax Controversy Forum
2023-06-08 14:10 - 15:00 (America/New_York)
On June 8, 2023, Jay Nanavati moderates a panel titled “Puerto Rico’s Act 20/22 Tax Incentive Program: Residency And Sourcing Under The IRS’s Microscope” at the 2023 NYU Tax Controversy Forum.
Description:
Since their passage in 2012, Puerto Rico’s Acts 20 and 22, known together as Act 60 since 2019, have encouraged many individuals and businesses from the U.S. mainland to relocate to Puerto Rico. The tax benefits that Act 60 provides encourage taxpayers outside Puerto Rico to boost the Puerto Rican economy by investing, doing business, and residing in Puerto Rico. As with any tax benefit, though, Act 60 is vulnerable to abuse. This panel discusses the IRS and the DOJ’s scrutiny of taxpayers’ claims of bona fide residency and Puerto Rico-sourced income.
Moderator:

Jay R. Nanavati, Esq., Partner, Kostelanetz, Washington, DC

Panelists:

Timothy P. Noonan, Esq., Partner, Hodgson Russ, New York, NY
Carlos F. Ortiz, Esq., Partner, Baker & Hostetler, New York, NY
Victor Song, Chief Operating Officer, Integritas3, Seattle, WA

Click here to learn more and register.

Christopher Ferguson Moderates A Panel Titled "Employee Retention Credit Audits And Investigations - The Tsunami Is Coming" At The 2023 NYU Tax Controversy Forum
2023-06-08 15:20 - 16:10 (America/New_York)
On June 8, 2023, Christopher Ferguson moderates a panel titled “Employee Retention Credit Audits and Investigations – The Tsunami is Coming” at the 2023 NYU Tax Controversy Forum.
Description:
​Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. Almost everyone has seen a commercial or received a text or email offering easy money through ERC claims. The IRS has made no secret of its plans to aggressively audit ERC claims and punish abuse and fraud. This panel of experienced practitioners discusses the IRS’ targeted enforcement efforts, explains how to spot red flags indicating abuse of the ERC, and describes the penalties that apply to taxpayers, promoters, and practitioners for erroneously claiming ERC credits.
Moderator:

Christopher M. Ferguson, Esq., Partner, Kostelanetz, New York, NY

Panelists:

Sandra R. Brown, Esq., Principal, Hochman, Salkin, Toscher, Perez, Beverly Hills, CA
Eric Hylton, Director of Investigations, Zerbe, Miller, Fingeret, Frank & Jadav, Washington, DC
Daniel Mayo, Esq., Principal, Withum, Red Bank, NJ

Click here to learn more and register.

Andrew Weiner Moderates A Panel Titled “The Administrative Procedure Act v. The IRS: Which Regulations, Rules, And Notices Will Survive?” At The NYU Tax Controversy Forum
2023-06-08 16:30 - 17:30 (America/New_York)
On June 8, 2023, Andrew Weiner moderates a panel titled “The Administrative Procedure Act v. The IRS: Which Regulations, Rules, And Notices Will Survive?” at the NYU Tax Controversy Forum.
Description:
Ever since the Supreme Court rejected tax exceptionalism in Mayo Foundation v. United States, 562 U.S. 44 (2011), challenges to tax regulations and IRS notices have proliferated, with several important decisions coming out in the last year alone. Courts have now developed a full body of jurisprudence regarding application of the Administrative Procedure Act (“APA”) to tax cases and it appears that Treasury and the IRS are going to have to engage much more carefully with the APA as they issue new guidance. Have we reached the end of “tax exceptionalism”? What does Treasury’s “Policy Statement on the Tax Regulatory Process” mean for deference in tax litigation? How will the APA apply to the blizzard of new guidance under the TCJA and increasingly the IRA? What might a post-Chevron world look like if, as some anticipate, the Supreme Court overrules the seminal decision next term? This panel addresses these questions and explores the current state of the law on the APA as it applies to tax.
Moderator:

Andrew Weiner, Esq., Counsel, Kostelanetz, Washington, DC

Panelists:

David W. Foster, Esq., Partner, Kirkland & Ellis, Washington, DC
S. Starling Marshall, Esq., Partner, Crowell & Moring, New York, NY
Joseph A. DiRuzzo, Ill, Esq., CPA, Partner, DiRuzzo & Company, Fort Lauderdale, FL

Click here for more information and to register.

Garrett L. Brodeur Moderates A Panel Titled "Navigating The Crypto Winter - Preparing For Cryptocurrency Regulation And Enforcement In Uncertain Times" At The 2023 NYU Tax Controversy Forum
2023-06-08 16:30 - 17:30 (America/New_York)
On June 8, 2023, Garrett L. Brodeur moderates a panel titled “Navigating The Crypto Winter – Preparing For Cryptocurrency Regulation And Enforcement In Uncertain Times” at the 2023 NYU Tax Controversy Forum.
Description:
The cryptocurrency industry is constantly changing and its underlying technologies are undeniably confusing. Faced with these obstacles, the IRS has issued informal guidance on discrete and nuanced tax issues, Treasury is poised to propose new information reporting rules, and regulatory scrutiny is tightening from all directions. This panel discusses the latest issues involving digital assets and highlights important considerations for tax counsel.
Moderator:

Garrett L. Brodeur, Esq., Associate, Kostelanetz, New York, NY

Panelists:

Thomas E. Bishop, Tom Bishop & Associates, East Islip, NY
Erika Nijenhuis, Esq., Senior Counsel, Office of Tax Policy, US Department of Treasury, Washington, DC
Del Wright Jr., Esq., Professor of Law, University of Missouri-Kansas City Law School, Kansas City, MO
Caitlin R. Tharp, Esq., Associate, Steptoe & Johnson, Washington, DC

Click here to learn more and register.

Don Fort Moderates A Panel Titled “IRS Criminal Investigation Division Enforcement Update” At The NYU Tax Controversy Forum
2023-06-09 08:45 - 09:45 (America/New_York)
On June 9, 2023, Don Fort moderates a panel titled “IRS Criminal Investigation Division Enforcement Update” at the NYU Tax Controversy Forum.
Description:
With the increase in the IRS enforcement budget coupled with the recent focus on fraud enforcement, tax professionals anticipate a surge in criminal tax investigations and prosecutions. This panel features James Lee, Chief of IRS Criminal Investigation, and top criminal tax defense experts on the latest trends and developments in criminal tax. Topics include enforcement priorities, technological innovations and data analytics, public-private partnerships, IRS funding and developments in cryptocurrency enforcement. Practitioners share practical tips on working with IRS-CI and tips on how to navigate the sensitivities of an IRS criminal investigation.
Moderator:

Don Fort, Director of Investigations, Kostelanetz, Washington, DC

Panelists:

James Lee, Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC
Kathy Enstrom, MBA, Director of Investigations, Moore Tax Law Group, Chicago, IL
Jeremy H. Temkin, Esq., Principal, Morvillo Abramowitz Grand Iason & Anello, New York, NY

Click here for more information and to register.

Sharon L. McCarthy Participates In A Panel Titled “Flipping The Script: Putting The Government On Defense At Trial” At The NYU Tax Controversy Forum
2023-06-09 13:30 - 14:20 (America/New_York)
On June 9, 2023, Sharon L. McCarthy participates in a panel titled “Flipping The Script: Putting The Government On Defense At Trial” at the NYU Tax Controversy Forum.
Description:
Despite best efforts to reach alternative resolution, litigation is often the best or only option. This panel discusses effective trial strategies in civil and criminal tax trials. Topics for discussion include when to stipulate, what pretrial motions to consider, how to handle discovery disputes, what to look for when picking a jury, how to handle a cooperating witness, getting the most out of the Government’s Brady/Giglio obligations, identifying evidentiary issues, and more.
Moderator:

Jeffrey A. Neiman, Esq., Partner, Marcus Neiman Rashbaum & Pineiro, Fort Lauderdale, FL

Panelists:

Sharon L. McCarthy, Esq., Partner, Kostelanetz, New York, NY
Sara G. Neill, Esq., Shareholder, Capes, Sokol, Goodman & Sarachan, St. Louis, MO
Richard W. Westling, Esq., Member, Epstein Becker & Green, Washington, DC

Click here for more information and to register.

Andrew Weiner Presents A Webinar For The ABA Tax Section Administrative Practice Committee
2023-06-21 12:00 - 13:00 (America/New_York)
On June 21, 2023, Andrew Weiner presents a webinar regarding the potential federal tax implications of Loper Bright Enterprises v. Raimondo and the possible repeal of Chevron deference to the ABA Tax Section Administrative Practice Committee.
Description: Next term, the Supreme Court will consider in Loper Bright Enterprises v. Raimondo, Case No. 22-451, whether to invalidate Chevron deference paid to most agency regulations. The issue is central to how agencies operate, and Treasury and the IRS are no exceptions. Andy summarizes the case and the arguments made in the cert petition and then turns to trends in recent Supreme Court cases challenging regulations to anticipate where the Court may be going.

Caroline D. Ciraolo Presents On Bedrosian v. United States To The ABA Tax Section Administrative Practice Committee
2023-06-21 12:00 - 13:00 (America/New_York)
On June 21, 2023, Caroline D. Ciraolo discusses Bedrosian v. United States with the ABA Tax Section Administrative Practice Committee.
Description: On June 20, 2023, the Supreme Court denied a petition for writ of certiorari in Bedrosian v. United States, Case No. 22-598, one of the longest running cases involving the imposition of willful civil penalties for failure to file an accurate Report of Foreign Bank and Financial Accounts (FBAR). Caroline Ciraolo will walk through the history of the Bedrosian case, starting with the relevant facts and circumstances, including the background of Mr. Bedrosian, to the administrative examination and appeal, and through the layers of litigation before the U.S. District Court for the Eastern District of Pennsylvania, the U.S. Court of Appeals for the Third Circuit, and the U.S. Supreme Court.

Caroline D. Ciraolo Presents On A Panel Titled "Coming in from the Cold: The Future of Voluntary Disclosures" For The CPA Academy
2023-06-28 12:00 - 13:00 (America/New_York)
On June 28, 2023, Caroline D. Ciraolo participates in a panel titled “Coming in from the Cold: The Future of Voluntary Disclosures” for the CPA Academy.
Description:
For more than 70 years, the IRS has had a voluntary disclosure policy designed to encourage taxpayers to come in from the cold and self-report noncompliance. In 2018, the voluntary disclosure program was updated to provide new procedures. The Taxpayer Advocate Service noted that the new procedures are substantially more onerous and uncertain than the old procedures and may actually discourage taxpayers from stepping forward to self-disclose. This panel will discuss the latest voluntary disclosure procedures, including the application of the program to cryptocurrency, and provide suggestions on how practitioners should advise their clients to make the best use of the new voluntary disclosure procedures.
Moderator:

Phillip J. Colasanto, Withersworldwide

Panelists:

Caroline D. Ciraolo, Kostelanetz LLP
Daniel N. Price, Law Offices of Daniel N. Price, PLLC
Michel Stein, Hochman Salkin Toscher Perez, P

John D. Fort Participates In A Summit Titled “Robots and Robbers: Financial Crime Technology Summit” At The Financial Crime Academy
2023-07-11 08:30 - 09:45 (America/New_York)
On July 11, 2023, Don Fort provides opening remarks and will lead a panel of experts to open the summit titled “Robots and Robbers: Financial Crime Technology Summit,” a three-day virtual financial crime summit presented by The Financial Crime Academy.
Description:
Technology has made great advancements in the financial world, from mobile banking to biometrics, artificial intelligence to machine learning, cryptos to NFTs. The digitalization of finance enables people and businesses to transact faster, expand their global reach, and access more channels than ever before. This radical change also makes things easier for criminals and money launderers. As illicit financing threats continue to evolve in their digital nature, there has been a transformative impact on the world of financial crime. Financial technology (FinTech) is evolving at a lightning pace, creating opportunities for criminal threats like fraud, cyber-attacks, sanctions evasion, corruption, and terrorism financing to go undetected. And now with the recent explosion of AI, the world of compliance and financial crime investigations will never be the same.
There is hope! Financial Crime Fighters are out there and dedicated to the prevention and investigation of money laundering and other illicit financing threats. Law enforcement, banking professionals and compliance experts must expand their technical knowledge and build a strong set of digital skills to prepare for the future. It’s not enough to know the laws and regulations; you must learn how financial crime is being conducted in this digital age.
Join the Financial Crime Academy for this first ever virtual event designed to enhance the knowledge and skills of aspiring financial crime fighters. You will leave with the ability to immediately add value to any anti-financial crime program.
Click here for more information and to register.

Megan L. Brackney Presents On "Ethical Issues In Practice Before The IRS" For The CPA Academy
2023-07-11 11:00 - 12:00 (America/New_York)
On July 11, 2023, Megan L. Brackney presents a webinar on “Ethical Issues in Practice Before the IRS” for the CPA Academy.
Description: This session covers the provisions of Circular 230 and the AICPA Statements on Standards for Tax Services that apply when interacting with the IRS during audits, appeals, collection matters, and other circumstances. Megan L. Brackney discusses the duty to provide information to the IRS and prolong the proceedings, diligence as to the accuracy of information presented to the IRS, and reliance on clients for information. She also discusses the civil and criminal penalties that apply to practitioners who violate these standards.
Learning Objectives:

Recognize the ethical rules that apply when interacting with the IRS
Determine when it is reasonable to rely on clients for information that is being presented to the IRS
Recall potential penalties that apply to practitioners who run afoul of these rules
Present tips for dealing with clients on these issues and correcting any misstatements made to the IRS

CPE credit may be offered for attendance.
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Caroline Ciraolo Appears On Tax Chat! Series On Transforming Tax Administration Entitled "IRS Penalty Policy and Practice" At The Center for Taxpayer Rights
2023-08-15 12:00 - 13:00 (America/New_York)
On August 15th, 2023, Caroline Ciraolo participates in a webinar panel titled “IRS Penalty Policy and Practice” as part of a webinar series titled “Transforming Tax Administration” presented by Center for Taxpayer Rights.
Description: Center for Taxpayer Rights presents a series of webinars from March 23, 2023 through August 31, 2023, titled Transforming Tax Administration. Each Tax Chat! touches on a separate topic.
If those interested already attended one of the Tax Chats! in this series, there’s no need to sign up again – a Zoom link will be sent via email. For those new to the series, you may sign up for the free online program here.
Panelists: Caroline Ciraolo of Kostelanetz LLP, Eric LoPresti of the US Senate Finance Committee, Susan Morgenstern of the Center for Taxpayer Rights, and Bob Probasco, Director of the Tax Dispute Resolution Clinic at Texas A&M University School of Law.

Heather Fincher Participates In A Webinar Entitled "Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies" For Strafford
2023-08-22 13:00 - 14:50 (America/New_York)
On August 22, 2023, Heather Fincher participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford. CPE Credit is offered for this event.
Description: This course provides tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact of IRS regulations requiring 5472 reporting by disregarded entities (DREs) with foreign owners. The panel provides line-by-line guidance on completing the form, defines complex concepts, and discusses the impact of IRS rules expanding filing requirements.
Panelists: Heather Fincher, Kostelanetz LLP and John Samtoy, Holthouse Carlin & Van Trigt LLP.
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Michael Sardar Participates In A Webinar Panel Titled "Nuts and Bolts of Tax Litigation: Administrative Process Summary, Choice of Forum, Initiating a Case" For The ABA Tax Section
2023-08-23 13:00 - 14:30 (America/New_York)
On August 23, 2023, Michael Sardar participates in a webinar panel titled “Nuts and Bolts of Tax Litigation: Administrative Process Summary, Choice of Forum, Initiating a Case” for the ABA Tax Section. CLE credit is offered for this event.
Description: This is the first of a four-part webinar series discussing the “nuts and bolts” of tax litigation. In this introductory webinar, the panelists provide an overview of the administrative process that precedes nearly all tax cases. The panelists also discuss where a case should be (or can be) filed and how to file it.
This webinar series is a partnership between the Tax Section’s Young Lawyers Forum and Court Procedure & Practice committee.
Panel Moderator: Ian Atkinson, Schonekas, Evans, McGoey & McEachin, L.L.C.
Panelists: Michael Sardar, Kostelanetz LLP; Jeffrey Glassman, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP; Fran Obeid, MFO Law, PC; Abbey Garber, Holland & Knight LLP; Aaron Esman, Moore Tax Law Group.
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