ABA 17th Annual U.S. and Latin America Tax Practice Trends Conference
2025-06-18 - 2025-06-20
Kostelanetz attorneys Heather Fincher, Eduardo A. Cukier, and Caroline D. Ciraolo will be speaking at the ABA’s 17th Annual U.S. and Latin America Tax Practice Trends Conference held in Miami from June 18 to June 20, 2025.
This year’s conference will focus on cross-border tax practice trends for multinational corporations and other business and investment vehicles, high net worth individuals and family offices, and their international advisors, as well as provide insight into how government tax officials may view the international tax landscape in light of important international developments that impact taxpayers. Panelists will include industry leaders, senior government officials, and leading tax practitioners from the United States, Latin America, and Europe.
The ABA will seek 15 hours of CLE credit in 60-minute states and 18 hours of CLE credit in 50-minute states. Credit hours are estimated and are subject to each state’s approval and credit rounding rules.
Please join Kostelanetz attorneys for the following sessions:
Wednesday, June 18, 2025, 2:00 PM – 3:30 PM Wealth Management Session
HNW Clients and Trusts: Contemporary Trends and Challenges in Latin America
Heather Fincher will co-chair a panel on cross-border planning and complexities related to the increasing use of trusts by advisors to high-net-worth individuals throughout Latin America and the United States.
Heather will be speaking with fellow Co-Chair Hermano A. C. Notaroberto Barbosa, BMA, São Paulo and speakers José Maurício C. Abreu, Farroco Abreu Advogados, São Paulo; Alil Álvarez Alcalá, Álvarez Alcalá, SC, Mexico City; Myriam Bril, Goldman Sachs, Miami, FL; Corina Laudato, Mitrani Caballero, Buenos Aires; Javier Otegui, Guyer & Regules, Montevideo; and Jennifer J. Wioncek, Bilzin Sumberg, Miami, FL.
Wednesday, June 18, 2025, 4:00 PM – 5:30 PM Wealth Management Session
New Frontiers for Family Offices: Emerging Issues for Cross-Border Family Office Structures and Investments
Eduardo Cukier will be speaking on U.S. tax and legal complexities faced by global family offices and their opportunities in structuring cross-border operations and investments.
Eduardo will be speaking alongside Co-Chairs Seth J. Entin, Greenberg Traurig LLP, Miami; Carola Trucco Horwitz, Barros & Errázuriz, Santiago; and speakers Paulo Bento, Madrona Advogados, São Paulo; Guadalupe Diaz-Sunico, Gomez-Acebo, Barcelona, and Gabriela Pellón, Galicia, Mexico City.
Friday, June 20, 2025, 11:00 AM – 12:30 PM Concurrent Session B
Defending Multiple Fronts – The Prevalence, Perils, and Best Practices of Parallel Civil and Criminal Tax Enforcement Proceedings
Caroline Ciraolo will co-chair the panel discussion on a range of issues practitioners face when dealing with parallel civil and criminal tax enforcement proceedings.
Caroline will be joined by fellow Co-Chair Luis Suárez de Centi, Uría Menéndez, Madrid; and speakers Mario Barrera, Clark Hill, Mexico City; Juan Carlos Casellas, Mayora & Mayora, S.C., Guatemala City; Barbara R. Llanas, Gelber Schachter & Greenberg, P.A., Miami, Florida, Luis Marcelo Nuñez, Perez Alati, Grondona, Benites, & Arntsen, Buenos Aires; and Alvaro Villegas, Villegas Aldazosa & Asociados, La Paz, Bolivia.
Full conference agenda and registration info available here.
About Heather
Heather focuses her practice on multinational businesses and high net-worth individuals in need of international tax planning. She counsels both U.S.- and foreign-owned businesses and individuals regarding the U.S. tax consequences of cross-border investments, cryptocurrency issues, mergers and acquisitions, joint ventures and restructurings. Heather also regularly advises clients on special issues arising in international tax controversies. Heather is also the co-founder of the ABA’s Women in Tax Forum.
About Eduardo
Eduardo’s transactions-based domestic and international tax practice spans more than two decades advising U.S. and foreign clients across many different types of business deals in various industries. Eduardo brings an international perspective, cultural awareness, and an understanding of legal and tax systems, regulatory frameworks, and the business dynamics involved in getting deals done. That skill set has made him counsel of choice for many corporations, businesses, and entrepreneurs in the U.S., Latin America, and around the globe.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s Washington, D.C. office. Her practice focuses on federal, state, and cross-border civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

2025 NYU Tax Controversy Forum
2025-06-26 - 2025-06-27
Kostelanetz LLP is pleased to be the primary sponsor of the 17th Annual NYU Tax Controversy Forum, which will be held on Thursday and Friday, June 26 and 27, 2025, at the Westin New York at Times Square.
For more than 17 years, Kostelanetz LLP and the NYU School of Professional Studies have brought together government representatives and expert private practitioners to share their perspectives on a variety of topics involving federal tax audits, appeals, and litigation for the annual Tax Controversy Forum. The forum covers a wide range of controversy work, from procedural seminars to substantive programs, international issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties.
For more information on the agenda and registration, click here.

Webinar: Tax Implications of Business Transfers and Exit Strategies
2025-09-19
Usman Mohammad will present a session titled “Tax Implications of Business Transfers and Exit Strategies” for the National Business Institute’s (NBI) “Prevent Undue Tax Burdens for Your Business Clients” full-day webinar. The webinar is on September 19, 2025, and will run from 10 a.m.-5 p.m. Eastern, with Usman’s session at 2:15 p.m. to 2:45 p.m.
NBI’s “Prevent Undue Tax Burdens for Your Business Clients” program is dedicated to small business and pass-through tax law issues, and it is designed to make tax and legal knowledge accessible for attendees who may not have prior tax law knowledge. The all-day webinar will cover a wide variety of tax topics pertinent to pass-through entities ranging from entity selection to international tax planning for closely-held businesses.
Usman’s session, “Tax Implications of Business Transfers and Exit Strategies,” will explore the taxation aspects of common small business exit strategies like selling a business and acquisition by a larger company.
You can learn more about the webinar and register here.
About Usman
Usman’s tax controversy practice includes defending clients in federal and state criminal matters involving issues such as tax shelters, payroll tax, check cashing, structuring cash deposits, filing false returns, and failing to file tax returns. He also has extensive experience with government procurement award protests, Article 78 proceedings involving procurement matters, foreign asset reporting issues, IRS responsible person and trust fund recovery penalty matters, IRS whistleblower matters, and IRS collection cases.

Annual Meeting of the National Association of State Bar Tax Sections
2025-09-25
Caroline Ciraolo and Andy Weiner will speak at the 46th annual meeting of the National Association of State Bar Tax Sections (NASBTS) hosted by the Washington State Taxation Section at Fox Rothschild LLP’s offices in Seattle, WA, from September 25-26, 2025.
The conference offers a wide variety of sessions in state, local, and federal taxation and tax controversy topics. Additionally, the Tax Section Boot Camp and NASBTS annual business meeting will take place at the conclusion of the day’s panels on Thursday, September 25. Continuing education credits are available.
Caroline’s panel on Thursday, September 25, from 8:15 a.m. to 9:15 a.m. Pacific is titled “Dealing with the New IRS: The State of IRS Enforcement and Its Impact on Dispute Resolution.” Panelists will discuss audit and dispute resolution trends in light of changes to the IRS in 2025. The panel will be moderated by Jaye Calhoun of Kean Miller, and Caroline will be joined by fellow panelists Parisa Griess of McDermott Will & Emery and Kevin Baker of Kean Miller.
Andy’s panel, “Federal and State Partnership Audits: Current Issues,” is on September 25 from 12 p.m. to 1 p.m. This panel will provide an overview of the centralized partnership audit regime under the Bipartisan Budget Act of 2018 (BBA), its implications for state tax systems and clients, and practice trends and strategies. The panel is moderated by Alexander Korzhen of Wagner Tax Law, and Andy will be joined by fellow panelist Kate Kraus of Covington.
You can learn more about the conference and register here.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
About Andy
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has argued approximately 50 tax cases in the U.S. courts of appeals. He is a Forbes contributing columnist on tax controversy and tax policy and a frequent writer and speaker on tax issues. He is also a fellow of the American College of Tax Counsel.

NYC Bar Webinar: Ethical Considerations for Corporate Investigations
2025-09-29 14:00 - 17:00 (America/New_York)
Sharon McCarthy will participate as a panelist in a New York City Bar webinar titled “Ethical Considerations for Corporate Investigations: Views from All Sides” on September 29, 2025, from 2 p.m. to 5 p.m.
The annual update program will explore current issues and recent developments related to ethical duties and responsibilities of attorneys in internal investigations involving corporations, counsel for current and former employees, and counsel for government agencies.
Registration and event information is available here.
About Sharon
Sharon, a Fellow of the American College of Trial Lawyers, has extensive experience representing individuals and corporations in white-collar criminal matters, civil and criminal tax controversies, and complex commercial litigation. Sharon conducts sensitive internal investigations for corporate and institutional clients either facing potential criminal charges or whose officers or employees have engaged in misconduct. She serves as the Independent Hearing Officer for the District Council of New York City and Vicinity of the United Brotherhood of Carpenters and Joiners of America and is on a panel of attorneys who advise and assist the Grievance Committee of the United States District Court for the Southern District of New York. She is an Adjunct Professor at Fordham Law School, where she teaches Trial Advocacy.

Practicing Law Institute: Trial by Jury 2025
2025-10-16
Sharon McCarthy will lead a panel titled “Closing Big: Delivering a Compelling Closing Argument” during the Practicing Law Institute Trial by Jury 2025 program at 4 p.m. Eastern on October 16, 2025.
This program provides a unique view into jury trials by practitioners and judges, from opening statements through closing arguments. The event is open to attorneys and allied professionals who want to learn about all aspects of handling jury trials.
Sharon will be joined by panelists Richard M. Strassberg, Partner at Goodwin Procter; the Hon. Eric R. Komitee, United States District Judge for the Eastern District of New York, and Hon. Vernon S. Broderick, United States District Judge for the Southern District of New York.
Registration and event information is available here.
About Sharon
Sharon, a Fellow of the American College of Trial Lawyers and former federal prosecutor, has extensive experience representing individuals and corporations in white-collar criminal matters, civil and criminal tax controversies, and complex commercial litigation. She is an Adjunct Professor at Fordham Law School, where she teaches Trial Advocacy.

Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know
2025-10-22 16:45 - 17:45
Michael Sardar will participate on a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Corporate Tax Advisor Should Know” for the Practising Law Institute’s conference on Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings.
The panel, which will be held on Oct. 22, 2025, at 4:45 p.m., will focus on the various judicial doctrines and ethical issues that arise in the corporate tax planning process. After completing this session, participants will be able to:

Identify the ethical rules related to advising clients on corporate transactions, 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
Avoid civil and criminal penalties potentially applicable to taxpayers and practitioners

Michael will be joined by S. Starling Marshall of Crowell & Moring LLP.
For more information, click here.
About Michael
Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.

41st Annual UCLA Tax Controversy Conference
2025-10-23
Kostelanetz attorneys Andrew Weiner, Bryan C. Skarlatos, and Karen Kelly will speak at the 41st Annual UCLA Tax Controversy Conference at the Beverly Hills Hotel in Los Angeles on October 23, 2025. Continuing education credit is offered, and attendance is in-person only. Kostelanetz is a proud Silver sponsor of this conference. Kostelanetz partner Caroline D. Ciraolo will also be in attendance at the conference.
Our attorneys will present the following sessions:
Thursday, Oct. 23, 2025, from 2:10 p.m. to 3:10 p.m. Pacific
“Valuation in Tax Enforcement Critical to Our Voluntary Compliance System”
Kostelanetz participant: Andy Weiner
Thursday, Oct. 23, 2025, from 3:10 p.m. to 4:10 p.m. Pacific
“Navigating IRS Resource Challenges – From the Taxpayer Advocate Service to Self-Help Options for Taxpayers and Tax Professionals”
Kostelanetz participant: Bryan Skarlatos
Thursday, Oct. 23, 2025, from 4:45 p.m. to 5:50 p.m. Pacific
“The Future Direction of Criminal Tax Enforcement”
Kostelanetz participant: Karen Kelly
You can learn more about the conference and register here.
About Andy
Andy focuses his practice on tax controversies, both civil and criminal, at all stages of the administrative and judicial process. A former U.S. Department of Justice attorney, he has argued approximately 50 tax cases in the U.S. courts of appeals. He is a Forbes contributing columnist on tax controversy and tax policy and a frequent writer and speaker on tax issues. He is also a fellow of the American College of Tax Counsel.
About Bryan
Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.
About Karen
The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. She was twice honored by the Department of Justice with the Attorney General Award for Outstanding Service. Her practice focuses on defending clients in state and federal criminal tax and white-collar investigations and prosecutions and representing clients in government investigations and enforcement actions. Karen draws on her extensive government experience to provide clients with insight and nuanced risk assessments and to provide a common-sense approach to best steps forward in complex criminal matters.

Hawaii Tax Institute 2025
2025-11-04 - 2025-11-05
Caroline D. Ciraolo will join two panels at the 2025 Hawaii Tax Institute scheduled for November 2-6, 2025, at the Sheraton Waikiki Resort in Honolulu. Continuing education credit is offered for attendees, and virtual attendance options are available.
Tuesday, Nov. 4, 2025 1:30 p.m. to 2:30 p.m. HST
Exempt Organizations Under Attack: Defending Exempt Status
In this session, Caroline will join Sarah Green, senior attorney at Dentons, and Rachel Leiser Levy, principal of Deloitte Tax LLP’s Washington National Tax division and former IRS Associate Chief Counsel, Employee Benefits, Exempt Organizations and Employment Taxes, to discuss the risks that exempt organizations face in the current political environment and how practitioners can best advocate for their exempt organization clients. Topics will include the processes by which organizations obtain exempt status, IRS audit procedures for exempt organizations, established IRS procedures likely to seek revocation of exempt status, and how to challenge proposed and final revocations.
Wednesday, November 5, 2025 1:30 p.m. to 2:30 p.m. HST
Clemency, Pardons, and Commutations: Navigating the Rules, Managing Client Expectations, and Ethical Considerations
In this session, Caroline will join Sandra Brown, shareholder of Hochman Salkin Toscher Perez PC and former Acting U.S. Attorney, Central District of California, and Sharyn Fisk, associate accounting professor at Cal Poly Pomona’s College of Business Administration and former Director of the IRS Office of Professional Responsibility, to review the legal, practical, and ethical issues relevant when advising clients facing criminal investigations or dealing with prior convictions and are curious about seeking pardons.
You can learn more about the conference and register here.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes

2025 Insurance Tax Conference
2025-11-06
Melissa Wiley will present at the 50th Annual Insurance Tax Conference at the Hyatt Regency in New Orleans, LA, on November 6, 2025.
Melissa’s session, “Tax Controversy: How to Deal with the IRS in the Current Environment,” will provide attendees with insights on how to resolve their clients’ IRS issues amid reduced agency staff and shifting priorities.
You can learn more about the conference and register here.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. An actuary by training, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

NYSSCPA Tax and Financial Planning for Individuals Conference
2025-11-06
Frank Agostino will present a session at the NYSSCPA Tax and Financial Planning for Individuals Conference on November 6, 2025, at the FAE Learning Center in New York, NY. Continuing education credit and virtual attendance options are available.
Frank’s session covers the “One Big Beautiful Bill” (OBBB) and the numerous sweeping changes for individual taxpayers. Attendees will learn about key provisions of OBBB, permanent changes including higher standard deductions, temporary tax benefits like the exclusion of tip income, and the above-the-line auto loan interest deduction. Frank will discuss tax planning opportunities arising from OBBB, like the revised SALT cap and comparisons of the tax benefits of the QBI deduction and tax-free capital gains from §1202 stock.
Frank will be joined by Walter Primoff, director of Perelson Weiner LLP.
You can learn more about the conference and register here.
About Frank
During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.

University of Chicago Law School Federal Tax Conference 2025
2025-11-07
Caroline D. Ciraolo will participate as a panelist in a session titled “Is Section 6103 Providing The Protections It Promised? And Should It?” at the University of Chicago Law School’s 78th Annual Federal Tax Conference on Friday, November 7, 2025, from 10:20 a.m. to 11:50 a.m. Central at the Gleacher Center.
The panel will be moderated by John Hildy, partner, Mayer Brown LLP, and will include a presentation by Joseph Thorndike, Contributing Editor, Tax Notes and Director, Tax History Project at Tax Analysts, regarding the historical context of Section 6103. Following the presentation, the panelists, including Caroline and Michael Desmond, member, Miller & Chevalier, and former IRS Chief Counsel, will engage in a discussion regarding the scope of Section 6103, the application and limitations of the many statutory exceptions, and current scrutiny in light of agreements between the IRS and other federal agencies to support the Administration’s enforcement priorities.
You can learn more about the conference and register here.
About Caroline
Caroline is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and now a partner with Kostelanetz LLP. Her practice focuses on federal, state, and cross-border civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Mental Health Issues in Tax Practice
2025-11-12 - 2025-11-14
Melissa Wiley will present a program titled “Mental Health Issues in Tax Practice” at the 2025 California All-Tax Conference hosted by the California Lawyers Association. The conference will be held at the Westin San Diego Bayview, November 12-14, 2025. Continuing education credit is available.
Melissa’s session takes place on Thursday, November 13, from 2:25 p.m. to 3:15 p.m. This session will cover how clients’ mental health struggles may affect their tax cases. Mental health issues can hide in plain sight, and practitioners often don’t think to ask about how their clients are doing mentally or consider how mental health issues may impact their case.
You can learn more about the conference and register here.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

AICPA National Tax Conference
2025-11-17 - 2025-11-18
Melissa Wiley will present two programs at the 50th AICPA & CIMA National Tax Conference taking place at the Washington Hilton in Washington, D.C., on November 17-18, 2025. Melissa is also a member of the planning committee for the AICPA National Tax Conference.
Continuing education credits and virtual attendance options are available.
Monday, November 17, 2025, 9:55 a.m. to 10:45 a.m. Eastern
Dealing With The IRS In The Current Era
This session will guide practitioners on how to work effectively with the IRS after recent reductions in the agency’s workforce, changes in leadership, funding cuts, and shifts in the agency’s priorities. Melissa will be joined by Mary Slonina of KPMG.
Tuesday, November 18, 2025, 11:20 a.m. to 12:35 p.m. Eastern
Working Effectively with the Taxpayer Advocate Service
This session will provide attendees with a deeper understanding of the Taxpayer Advocate Service’s (TAS) role within the IRS, how to best advocate for clients using TAS, and how to identify the criteria that make TAS more likely to accept a case referral. Melissa will be joined by Rochelle Hodes of Crowe LLP.
You can learn more about the conference and register here.
About Melissa
With more than 20 years of experience in tax law, Melissa has represented a diverse range of clients, from large corporations to high-net-worth individuals, in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, Melissa excels at distilling intricate tax issues into clear, actionable insights — helping her clients efficiently resolve disputes and focus on what matters most in their businesses and lives.

National Conference of CPA Practitioners 2025 Accounting and Tax Symposium
2025-11-19 - 2025-11-21
Kostelanetz attorneys Megan L. Brackney and Karen Kelly will speak at the Nassau/Suffolk chapter of the National Conference of CPA Practitioners (NCCPAP) 2025 Accounting and Tax Symposium. The conference will take place November 19–21, 2025, at the Crest Hollow Country Club in Woodbury, NY.
Megan’s session, “Circular 230: Rules and Best Practices for Tax Return Positions, Interacting with the IRS, and Assisting Clients with Past Non-Compliance,” will discuss key provisions of Circular 230 and how to best advocate for your clients while staying compliant. The panel will be held on November 21, 2025, from 1:05 p.m. to 2:20 p.m.
Karen’s session, “The Times They Are a-Changing,” will discuss the types of cases that IRS Special Agents are now focused on under the current administration, how cases will be worked and referred for criminal prosecution going forward, and expectations for the future of voluntary compliance with the tax laws in the United States. The panel will be held on November 20, 2025, from 12:45 p.m. to 1:40 p.m.
The three-day symposium is co-sponsored by NCCPAP and the IRS, covering a wide variety of taxation topics. Attendees will have the opportunity to earn up to 27.5 continuing education credits and resolve their cases in person with senior IRS staff and New York State Department of Taxation and Finance representatives.
You can learn more about the symposium and register here.
About Megan
Megan is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan is the Chair of the American Bar Association Section of Taxation. She is also a frequent speaker and contributor to local and national conferences on taxation, ethics in tax practice, IRS penalties, and civil tax controversy.
About Karen
The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations, and in criminal tax and white-collar state and federal matters.

12th Annual IRS Representation Conference
2025-11-19 13:00 - 17:00
Michael Sardar will speak on two panels at the 12th Annual IRS Representation Conference at the Foxwoods Resort Casino in Mashantucket, Conn., on November 19, 2025.
The IRS Representation Conference is the premier event for tax professionals who want to stay ahead of the fast-changing enforcement landscape. Leading attorneys, former IRS officials, and industry experts come together for a half-day program packed with insights, strategies, and practical tools you can use immediately in your practice.
The conference is from 1 p.m. – 5 p.m. Eastern. For more information, click here.
Michael’s panels include:

November 19, 2025, 1:00 pm – 2:00 pm
IRS Enforcement Update
Michael will be joined by Eric Green of Green & Sklarz LLC and Mary Beth Murphy, Former IRS SB/SE Commissioner.

November 19, 2025, 2:00 pm – 3:00 pm
Where’s My Money? Obtaining Refunds Amidst IRS Chaos
Michael will be joined by Jeffrey Sklarz and Lisa Perkins, both of Green & Sklarz LLC.

About Michael
Michael represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.

UT Law CLE 2025 Taxation Conference: What to Do With All the Data?
2025-12-04
Melissa Wiley will present a program titled “What to Do With All the Data? Substantiating Tax Positions in the Face of Tidal Waves of Data” at the University of Texas School of Law CLE 73rd Annual Taxation Conference. The conference is being held at the AT&T Conference Center in Austin, TX on December 4, 2025. Continuing education credits and virtual attendance options are available.
Melissa’s session takes place from 10:45 a.m. to 11:45 a.m. Central. In this session, Melissa will discuss the role of Big Data in how taxpayers and practitioners interface with tax authorities, and how to best advocate for clients in the Digital Age.
You can learn more about the conference and register here.

2025 ABA Criminal Tax Fraud and Tax Controversy Conference
2025-12-11 - 2025-12-13
Several Kostelanetz attorneys will speak on various panels of the 2025 ABA Criminal Tax Fraud and Tax Controversy Conference, of which Kostelanetz LLP is a proud sponsor. Our attorneys will demonstrate their knowledge and experience in tax controversy, high-profile developments in tax enforcement, criminal tax litigation, and more.
The conference will be held December 11-13, 2025, at the Wynn Las Vegas. Continuing education credit is available for most sessions. You can learn more about the conference and register here.
Please join us for the following panels:
Thursday, December 11, 2025, 10:30 a.m. to 12:30 p.m.
Low-Income Taxpayers Workshop: Tax Representation for Student Athletes, Performing Artists, Influencers, and Content Creators: Understanding NIL and Beyond
Counsel Frank Agostino will moderate a panel about unique tax issues that affect modern-day influencers, content creators, and sports stars. Just like yesteryear’s movie stars, independent content creators and influencers with brand deals have a bevy of unique tax issues. There are additional tax complexities surrounding Name, Image, and Likeness (NIL) income for student athletes that adds layers to advising pro athlete clients on the “jock tax”. Attendees will leave with a more comprehensive understanding of this high-profile practice area and its evolutions in self-employment taxes, entity selection, multi-state tax issues, royalty income, and IRS initiatives targeting these groups.
Other panel participants include Anthony DeRiso of Jones Day and Sarah Green of Dentons.

Thursday, December 11, 2025, 2:30 p.m. to 5:30 p.m.
Civil Tax Workshop: Nuts and Bolts of Tax Controversy Practice: Trying Your Tax Court Case in An Electronic Courtroom
Counsel Frank Agostino will moderate a panel on civil tax issues. Tax Court judges and experienced trial lawyers will come together to teach attendees basic skills in civil litigation in the context of specific issues and procedures. In this annual workshop that explores how technology constantly changes law practice, the speakers will demonstrate best practices for trying cases in electronic courtrooms.
Frank will be joined by The Hon. Ronald L. Buch and Hon. Mark V. Holmes, Senior Judge, of United States Tax Court will join Christopher Gurley of Crowell & Moring LLP, Rami Mitri Khoury of Taylor Nelson Amitrano LLP, and Sarah Ray of Dentons.

Thursday, December 11, 2025, 2:30 p.m. to 5:30 p.m.
Civil Tax Workshop: Nuts and Bolts of Tax Controversy Practice: Trying Your Tax Court Case in An Electronic Courtroom
Counsel Frank Agostino will moderate a panel on civil tax issues, focusing on how technology is revolutionizing Tax Court practice. From filing petitions to monitoring deadlines and preparing exhibits for filing with the Court and examining witnesses, technology shapes how we present cases. This seminar will review the latest technological advancements and discuss their impact on civil tax litigation. Tax Court judges and experienced trial lawyers will come together to share insights on basic skills in civil litigation in the context of specific issues and procedures, and demonstrate best practices for trying cases in electronic courtrooms.
Counsel Frank Agostino will moderate this session. The Hon. Ronald L. Buch, Judge, United States Tax Court; The Hon. Mark V. Holmes, Senior Judge, of United States Tax Court; Christopher Gurley of Crowell & Moring LLP; Rami Mitri Khoury of Taylor Nelson Amitrano LLP; and Sarah Ray of Dentons.

Thursday, December 11, 2025, 2:00 p.m. to 5:30 p.m.
Criminal Tax Workshop
Jay Nanavati will co-moderate a workshop where attendees will learn strategies and techniques for sensitive civil examinations, criminal investigations, and defending criminal prosecutions. Attendees will also receive a “criminal tax toolkit” of best practices from experienced practitioners. Workshop topics include when to anticipate a criminal referral, how to handle IRS Special Agent interviews of taxpayers and preparers, representing parties in criminal investigations, and more.
Mike Waalkes will introduce the workshop and Mary Wood of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, will co-moderate with Jay. They will be joined by Siana Danch of Holland & Knight LLP; Chad Nardiello of Nardiello Turanchik Tompkins LLP; Richard Speier of Richard Speier P.C.; and Anshuman A. Vaidya of Hinshaw & Culbertson LLP.

Friday, December 12, 2025, 8:40 a.m. to 9:25 a.m.
What Else Can We Do: Tax Controversy Practice in Challenging Times
Caroline Ciraolo will moderate this panel with former IRS Commissioners, Hon. Charles Rettig and Hon. Daniel Werfel, who will share their years of broad experience steering the IRS through myriad challenges.
This plenary panel will address taxpayer needs in an era where the IRS is expected to function with fewer resources, and the resources that exist are diverted to non-tax enforcement. How can tax controversy professionals utilize their skills to meet taxpayers’ needs and resolve cases?

Friday, December 12, 2025, 9:30 a.m. to 10:25 a.m.
Criminal Enforcement Priorities
Karen Kelly, Kostelanetz partner and the immediate past head of the Justice Department’s Tax Division, will participate in a roundtable of former IRS and DOJ leaders and prosecutors. The speakers will discuss hot topics and recent decisions in the criminal tax sphere in the context of current DOJ policies.
Sandra R. Brown of Hochman Salkin Toscher Perez P.C. will moderate. Karen will be joined in the roundtable by Guy Ficco, Chief, IRS Criminal Investigations; Elizabeth Hadden, Deputy Division Counsel, IRS Criminal Investigations; and Eric Hylton, National Director of Compliance, Alliantgroup.

Friday, December 12, 2025, 11:40 a.m. to 12:35 p.m.
Civil Tax: Exam, Collection, Appeals – Navigating Administrative Matters With a Reduced IRS Workforce
The IRS faces unprecedented challenges in resources, but taxpayers still need their civil tax matters resolved. Experienced practitioners will share their strategies and current approaches with attendees for navigating the current IRS landscape when handling existing examinations, IRS appeals, collections, and other civil tax matters.
Shan Kadkoy will introduce the session, which Guinevere Moore of Moore Tax Law Group will moderate. They will be joined by Abbey Garber of Holland & Knight LLP, Richard J. Sapinski of Sills Cummis & Gross P.C., and Carolyn Schenck of Caplin & Drysdale.

Saturday, December 13, 2025, 8:45 a.m. to 9:45 a.m.
Responding to Challenging Client Requests: Where Are the Ethical Lines?
Bryan Skarlatos will moderate a panel on the practical and ethical issues involved in addressing challenging requests from clients, such as assisting a client to use political influence to affect an audit or investigation, or seek a pardon. Or, whether a client can be extradited from a specific country, or can engage in asset protection planning.
Bryan will be joined by Michael J. Desmond of Miller & Chevalier; Diana Erbsen of DLA Piper; and Kathleen Pakenham of Vinson & Elkins LLP.

Saturday, December 13, 2025, 10:00 a.m. to 11:30 a.m.
Non-Traditional Tax Advocacy
Frank Agostino will moderate a session on non-traditional tax advocacy. Some tax cases cannot be resolved through standard procedures. How do you advocate for your client when letters to the IRS go unanswered, or Appeals is not responsive? This panel will discuss non-traditional routes to solving tax problems such as seeking redress from the Taxpayer Advocate Service and Treasury Inspector General for Tax Administration, contacting the client’s Congressional constituent services office, getting the Office of Professional Responsibility involved, and going to the media.
Frank will be joined by Stephen Cohen, Senior Managing Director and Co-Head, Transactions and Strategic Situations Group, Teneo; and Sharyn M. Fisk, Associate Professor at Cal Poly Pomona.

About Frank
During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of Kostelanetz’s Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
About Karen
The former head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations, including in criminal tax and white-collar matters, and against state and federal criminal charges.
About Jay
Jay is a criminal tax defense attorney and a fellow of both the American College of Trial Lawyers and the American College of Tax Counsel. He represents individuals and entities facing investigations and prosecutions by the IRS, the FBI, state investigative agencies, U.S. Attorney’s offices, and the Department of Justice Tax Division. Jay has defended clients against federal investigations and charges throughout the country, and he has substantial experience representing clients accused of promoting or participating in so-called tax shelters, including captive insurance programs, conservation easements, and Puerto Rico’s Act 20/Act 22 program. In many instances, Jay represents tax professionals facing such accusations.
About Bryan
Bryan focuses his practice on assisting clients with navigating tax penalties and voluntary disclosures. He provides expert testimony on tax penalties to governmental bodies and teaches courses on tax penalties at New York University School of Law, where he also created and co-chairs the NYU Tax Controversy Forum. Bryan is recognized by Super Lawyers as one of the Top 100 Lawyers in New York and Best Lawyers in America has twice named Bryan “Lawyer of the Year” for Tax Litigation in New York.
About Mike
Mike received his J.D. and LL.M. in taxation from Boston University School of Law. During law school, he worked as an intern for the low-income taxpayer clinic at Harvard Law School’s Legal Services Center, as a research assistant for Professor T. Keith Fogg of Harvard Law School, and as a summer associate and a law clerk with Kostelanetz. Mike also served as an editor on the Review of Banking and Financial Law journal. Prior to law school, Mike worked as a paralegal at a tax controversy firm in the D.C. metro area.
About Shan
Shan began his legal career as a Judicial Law Clerk to the Honorable Mary Siobhan Brennan, J.T.C., in the Tax Court of New Jersey. Prior to joining the firm, Shan practiced at Agostino & Associates P.C., as well as at another firm, concentrating his practice in Wills, Trusts & Estates, and Business Law.
