Tax Controversy 2025: Navigating the New Enforcement Landscape

Partner Bryan Skarlatos is co-chairing the Practising Law Institute’s (PLI) one-day program, Tax Controversy 2025: Navigating the New Enforcement Landscape, in New York City on March 24, 2025. Bryan will be joined by Michael J. Desmond of Miller & Chevalier as co-chair, and a myriad of experienced practitioners from other law firms and the IRS will present.

This full-day program will feature several panels that explore the nuances of federal tax controversy issues and how to recognize them before they become tax enforcement risks. Bryan and the other practitioners will walk attendees through the IRS examination process all the way from the initial audit plan through closing conferences, the administrative appeals process, Bipartisan Budget Act of 2015 (BBA) audit procedures, and areas in which the IRS is prioritizing enforcement actions.

Panels discussions in the program include:

• Handling an IRS Examination: This panel will explore processes such as the initial audit plan, information document requests, summonses, foreign information requests, third-party contacts, privileges, extensions of the statute of limitations and closing conferences.
• Unique Tax Controversy Issues Relating to Partnerships: This panel will focus on steps being taken by the IRS to coordinate partnership audits, discuss partnership-related campaigns and other areas of substantive focus, and provide insight into procedural aspects of the BBA rules, including the determination of imputed underpayments, when the modification rules may be useful, how the modification procedures are being implemented, and pitfalls to watch out for with push-out elections.
• IRS Enforcement Priorities: The session will identify areas of IRS enforcement, such as high-income cases, partnership issues, digital assets, Reports of Foreign Bank Accounts (FBAR) violations, employment tax issues, and promoted tax shelters. Panelists will address challenges the IRS will face as it endeavors to implement its strategic operating plan, complicated by issues flowing from tax administration in a global economy, including transfer pricing, competing jurisdictional claims for primary taxing rights, and double taxation and increased application of the Administrative Procedure Act to tax regulations and other guidance.
• Recent Tax Cases and Pending Litigation: This panel will review a number of pending and recently decided cases, including Moore, Loper Bright, Corner Post, Varian, 3M, Patel, Liberty Global, and Otay.
• Valuation and Valuation Disputes in Tax Cases: This panel will provide an overview of valuation concepts as they arise in tax cases, identify areas of common dispute and controversy, and summarize best practices for securing and defending valuations in tax cases.

After completing this day-long program, participants will be able to:

• Anticipate potential federal tax controversy issues before they arise
• Assist taxpayers in understanding the compliance and enforcement risks associated with uncertain tax reporting positions and in taking steps to mitigate those risks
• Effectively resolve issues in the IRS examination and administrative appeal process

The program is designed for tax attorneys, accountants and in-house tax professionals interested in obtaining a broader understanding of the process for handling tax controversy matters in the context of IRS audits and administrative appeal proceedings and key concepts that arise in tax controversy.

The full-day program will take place at PLI’s New York office on 1177 Avenue of the Americas (entrance on 45th Street). Virtual attendance options are also available. You can learn more about the program and register here.

About Bryan
For more than thirty-five years, Bryan has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice.