Kostelanetz LLP

Jay Nanavati Participates In A Panel For The DC Bar On The Corporate Transparency Act
2022-10-19 11:30 - 12:45 (America/New_York)
On October 19, 2022, Jay R. Nanavati addressed the DC Bar in a panel entitled “Corporate Transparency Act: Are You Ready?”.
Panel Description: When FinCEN recently issued its final regulations regarding who must report information under the Corporate Transparency Act, many practitioners shrugged and filed the story for future reading. While the regulations will not go into effect until January 1, 2024, there will be significant ground for reporting companies and their advisors to cover to prepare for the new reporting regime. What exactly is this new beneficial ownership database? Who must report, what information, and when? Come hear from a panel of seasoned civil and criminal tax controversy attorneys who have been closely tracking the developments in this area.
Speakers:

Jay Nanavati, Partner, Kostelanetz & Fink LLP
Joseph Rillotta, Member, Miller & Chevalier
Melissa Wiley, Member, Caplin & Drysdale, Chartered

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Don Fort Joins A Panel Titled "Criminal Tax Trends" At The 2022 Freeman Law International Tax Symposium
2022-10-20 09:40 - 22:30 (America/New_York)
Don Fort joins a panel titled Criminal Tax Trends at the 2022 Freeman Law International Tax Symposium. The symposium assembles tax experts from across the world to discuss tax trends that are reshaping international taxation. It sets the stage for attorneys to learn about topics such as global tax reform, international civil penalty enforcement, transfer pricing development, cryptocurrency global enforcement trends, and cross-border tax planning opportunities.
Panelists:

Don Fort, Director of Investigations, Kostelanetz & Fink, LLP
Carolyn Schenck, IRS National Fraud Counsel and Assistant Division Counsel (International)
Nanette Davis, Senior Litigation Counsel, Department of Justice Tax Division

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Caroline D. Ciraolo Joins A Panel Titled "International Tax & Trade Investigations And Voluntary Disclosures" At The 2022 Freeman Law International Tax Symposium
2022-10-20 10:40 - 23:30 (America/New_York)
Caroline Ciraolo joins a panel titled “International Tax & Trade Investigations and Voluntary Disclosures” at the 2022 Freeman Law International Tax Symposium. The symposium assembles tax experts from across the world to discuss tax trends that are reshaping international taxation. It sets the stage for attorneys to learn about topics such as global tax reform, international civil penalty enforcement, transfer pricing development, cryptocurrency global enforcement trends, and cross-border tax planning opportunities.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP
Josh Wu, Counsel, Latham & Watkins LLP
Olga Torres, Managing Member, Torres Trade Law
Matthew Robert, Principal, Freeman Law

Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "From The Experts: Tax Controversy And Tax Litigation - Civil & Criminal Tax Update" At The 81st Institute On Federal Taxation
2022-10-23 13:15 - 15:45 (America/New_York)
Caroline D. Ciraolo participates in a panel titled “From The Experts: Tax Controversy And Tax Litigation – Civil & Criminal Tax Update” on October 23, 2022 at the 81st Institute on Federal Taxation in New York.
Panel Description: Join a leading group of tax controversy practitioners from both the private sector and the government in an open discussion regarding current IRS enforcement priorities, initiatives, and campaigns, including areas impacted by the Inflation Reduction Act of 2022 (IRA). The panel covers a broad range of topics that impact tax compliance and tax litigation, including an examination of recent cases, investigations, and programs – such as the IRS’s new Emerging Issues Group – that reflect the government efforts to target high risk areas of noncompliance, including the increased role that the IRS Collection Division plays in tax administration, as well as approaches to representing and defending clients who are the focus of such investigations.
Panelists:

Frank Agostino, Esq., Founder & President, Agostino & Associates, PC, Hackensack, NJ
Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC
Kristina L. Rico, Esq., Senior Counsel, Office of Chief Counsel, Small Business/Self-Employed Division, National Fraud Counsel Team, Internal Revenue Service, Philadelphia, PA

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Garrett L. Brodeur Participates In A Panel Entitled "Exploring Tax Practice Settings With Alumni" For Students Of The Georgetown Law Center Tax LL.M. Program
2022-10-25 12:00 - 13:00 (America/New_York)
Garrett L. Brodeur participates in a panel titled “Exploring Tax Practice Settings With Alumni” for students of the Georgetown Law Center Tax LL.M. Program on October 25, 2022.
Panelists:

Garrett L. Brodeur, Kostelanetz LLP
Ballinger Doyle, Grant Thornton
Camilah Gould-Bailey, Google Tax
Saiya Savooji, KPMG Canada

This panel was only available to students of the Georgetown Law Center Tax LL.M. Program. Click here to view a recording of the panel.

Megan L. Brackney Participates In A Panel Entitled "When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice" At The 81st Institute On Federal Taxation
2022-10-27 17:15 - 18:55 (America/New_York)
Megan L. Brackney participates in a panel titled “When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice” on October 27, 2022 at the 81st Institute on Federal Taxation in New York.
Panel Description: How sure do you have to be before you tell a client it is okay to take a deduction or defer income? Do you have to audit a client’s records or can you just rely on what the client says? After the return has been filed, how do you handle an audit when you know the client’s tax return is wrong? What do you do if the information you submitted to the IRS is not accurate? When do you have to worry about conflicts of interest? While the answers to these questions may not always be clear, the law and related ethical standards provide very specific rules to help find the answers. This panel of expert practitioners addresses these and other thorny ethical issues that arise in everyday tax practice through the use of hypothetical examples. This program is essential for tax professionals who want to stay on the right side of the line.
Panelists:

Megan L. Brackney, Esq., Partner, Kostelanetz, New York, NY
Christopher S. Rizek, Esq., Member, Caplin & Dysdale, Chartered, Washington, DC

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Caroline D. Ciraolo Participates In A Panel Titled "Current Tax Disputes Trends at a Domestic and Cross Border Level" At The October IFA UK Branch Meeting
2022-10-27 18:00 - 19:30 (Europe/London)
Caroline D. Ciraolo joins a panel titled “Current Tax Disputes Trends at a Domestic and Cross Border Level” at the International Fiscal Associations UK branch meeting held on October 27, 2022.
Panel Description:
Panelists from around the world offer their unique perspectives on civil and criminal tax enforcement and trends in the United Kingdom, United States, Israel, India, and Finland.
Panelists:

Liesl Fichardt, Head of International Tax and Regulatory Investigations and Disputes, Quinn Emanuel, UK
Parul Jain, Co-Head, International Tax Practice, Nishith Desai Associates, India
Ofer Granot, Partner, Herzog, Fox & Neeman, Israel
Caroline Ciraolo, Partner, Kostelanetz LLP, Washington, DC
Jouni Weckström, Partner, Waselius & Wist, Finland

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Three K&F Attorneys Participate In Ethics Panels At The "Tax Strategies 2022" Conference
2022-10-28
Bryan Skarlatos, Caroline Ciraolo, and Megan Brackney serve as panelists at the Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2022 (“Tax Strategies 2022”) conference. The panel is titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know.”
Mr. Skarlatos serves as a panelist at the New York City Tax Strategies 2022 conference on October 28, 2022. Ms. Brackney speaks at the Chicago conference on November 18, 2022, and Ms. Ciraolo presents at the Los Angeles conference on December 9, 2022.
Panel Description:
Ethical rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit; the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct
Click here to register.

Caroline D. Ciraolo Participates In A Panel Entitled "Tax Treaties For The Estate Planner" At The California Lawyers Association Taxation Section's 2022 Annual Meeting Of The Tax Bar And Tax Policy Conference
2022-11-04 15:30 - 17:00 (America/Los_Angeles)
Caroline D. Ciraolo participates in a panel entitled “Tax Treaties for the Estate Planner” at the California Lawyers Association, Taxation Section’s 2022 Annual Meeting of the Tax Bar and Tax Policy Conference. The panel will discuss important issues under income, and estate and gift tax treaties. It will also cover the exchange of information under such treaties and/or FATCA agreements and other associated issues.
Panelists:

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

Click here to register. Please note that MCLE credit is being offered for this event.

Caroline D. Ciraolo Participates In A Panel Titled "Using the IRS's Taxpayer Advocate Service to Help Taxpayers Across the Country" At The 59th Annual Hawaii Tax Institute
2022-11-07 16:00 - 17:00 (Pacific/Honolulu)
Caroline D. Ciraolo joins a panel titled “Using the IRS’s Taxpayer Advocate Service to Help Taxpayers Across the Country” at the 59th Annual Hawaii Tax Institute. This panel will discuss how the IRS’s National Taxpayer Advocate can help taxpayers address federal tax issues and mitigate taxpayer problems. Explore the internal workings of the IRS’ Taxpayer Advocate Service, the kind of facts and cases they address/resolve, and how all federal taxpayers and their Wealth Transfer Advisors can use this “voice of the taxpayer”.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Kurt Kawafuchi, Principle, Law Offices of Kurt Kawafuch
Erin M. Collins, National Taxpayer Advocate, Internal Revenue Service

Click here to register. Please note the event will be taking place in PST time.

Caroline D. Ciraolo Participates In A Panel Titled "Foreign Trusts and Gifts - Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!" At The 59th Annual Hawaii Tax Institute
2022-11-08 13:30 - 14:30 (Pacific/Honolulu)
Caroline D. Ciraolo joins a panel titled “Foreign Trusts and Gifts – Reporting Obligations, Compliance Issues, and Challenging Those Egregious Penalties!” at the 59th Annual Hawaii Tax Institute.
We live in a global economy and many clients have sources of income and assets outside the United States. For U.S. persons, this means having to comply with a complex web of reporting obligations under the Internal Revenue Code and the Bank Secrecy Act. This panel will address reporting requirements for foreign trusts (including Australian Superannuation funds, Liechtenstein Anstalt, Mexican fideicomiso, Canada tax saving and retirement plans, Stiftungs, and Usufructs), and the receipt of gifts from foreign individuals and entities. Learn about the consequences of noncompliance, paths to compliance, and best practices in challenging the often substantial penalties.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Marsha Dungog, Partner, Withers Worldwide
Kurt Kawafuchi, Principle, Law Offices of Kurt Kawafuchi

Click here to register. Please take note that this event will take place in PST time.

Caroline D. Ciraolo and Don Fort Participate In A Panel Titled "When Aggressive Tax Planning Becomes Criminal Conduct" At The 59th Annual Hawaii Tax Institute
2022-11-10 12:30 - 13:30 (Pacific/Honolulu)
Caroline D. Ciraolo and Don Fort join a panel titled “When Aggressive Tax Planning Becomes Criminal Conduct” at the 59th Annual Hawaii Tax Institute.
High income taxpayers frequently look to minimize their tax burdens and tax professionals are only too happy to oblige with one planning structure or another. It is when these structures cross the line that the Government sounds the alarm. When tax-advantaged transactions are “too good to be true,” “lack economic substance,” “lack business purpose,” or are deemed to be economic scams, taxpayers and their advisors can face civil audits and promoter investigations, both resulting in substantial civil penalties, professional licensing issues, and injunctions. When the Government believes that the individuals involved intentionally violated the rules – lying, cheating, or stealing – the matter can quickly move into the criminal realm. This panel will review what causes the Government to initiate a criminal tax investigations, ethical considerations for wealth transfer advisors, the roles of IRS-CI, the Justice Department’s Tax Division, and the U.S. Attorney’s Office, the transactions and structures currently targeted by the IRS, and “ripped from the headlines” criminal tax prosecutions.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Don Fort, Director of Investigations, Kostelanetz LLP
Evan Davis, Principal, Hochman Salkin Toscher Perez PC
Rebecca Perlmutter, AUSA, U.S. Attorney’s Office, District of Hawaii

Click here to register. Please note the event will be taking place in PST time.

Bryan C. Skarlatos Participates In A Panel Discussion Entitled "Criminal Tax Enforcement" At The UCLA Extension 38th Annual Tax Controversy Institute
2022-11-14 11:00 - 19:50 (America/New_York)
Bryan C. Skarlatos participates in a panel discussion entitled “Criminal Tax Enforcement” on October 27th at the UCLA Extension 38th Annual Tax Controversy Institute. The virtual re-broadcast is available on November 14, 2022.
Panel Description:
This panel covers criminal tax proceedings arising under the Internal Revenue Service’s laws, including the roles of the criminal tax attorney, tax fraud investigations, and IRS criminal investigations.
Moderator:

Sandra R. Brown, Hochman Salkin Rettig Toscher & Perez, P.C.

Panelists:

Bryan C. Skarlatos, Esq., Kostelanetz LLP
Tyler R. Hatcher, IRS-CI Special Agent in Charge, Los Angeles Field Office
Damon Rowe, Meadows Collier Reed Cousins Crouch & Underman, LLP
Lorraine Yu, IRS Chief Counsel, Criminal Tax Counsel

Click here to register for the virtual re-broadcast.

Garrett L. Brodeur Speaks About Current Supreme Court Case, Bittner v. United States, At The ABA Tax Section Administrative Practice Committee November Meeting
2022-11-17 12:00 - 13:00 (America/New_York)
Garrett L. Brodeur speaks about the current Supreme Court case, Bittner v. United States (No. 21-1195), at the ABA Tax Section Administrative Practice Committee’s Monthly Lunch Meeting on November 17, 2022. The presentation will focus on the oral arguments heard before the Court on the morning of November 2nd, 2022.
Meeting Description: The meeting will cover updates on the following important and closely-watched cases:

U.S. v. Bittner, No. 21-1195: Is a “violation” under the Bank Secrecy Act the failure to file an annual FBAR or is there a separate violation for each individual account that was not properly reported. The Supreme Court heard oral arguments on November 2, 2022.
Green Valley Investors, LLC, 159 T.C. No. 5 (November 9, 2022): The US Tax Court held that the IRS could not impose penalties for failure to comply with Notice 2017-10, designating conservation easements as listed transactions, because the Notice skipped notice-and-comment rulemaking required under the Administrative Procedure Act.
In re Grand Jury Proceeding, No. 21-1397. On October 3, 2022, the Supreme Court granted certiorari to consider if a communication involves both legal and non-legal advice, when is it protected from disclosure by the attorney-client privilege?

Speakers:

Garrett L. Brodeur, Kostelanetz LLP, Co-Counsel for Amicus Curiae American College of Tax Counsel.
Susan Combs, Holland & Hart LLP.

Caroline D. Ciraolo Presents "Ethics: When Aggressive Tax Planning and Controversy Defense Become Criminal Conduct" At The 71st Tulane Tax Institute
2022-11-17 16:45 - 17:45 (America/New_York)
Caroline D. Ciraolo speaks on “Ethics: When Aggressive Tax Planning and Controversy Defense Become Criminal Conduct” at the 71st Tulane Annual Tax Institute on November 17th, 2022.
Taxpayers frequently look to minimize their tax burdens or avoid immediate payment of tax liabilities and tax professionals often assist with a variety of planning structures or defensive strategies. It is when these structures or strategies cross the line that the Government sounds the alarm. On the civil side, tax-advantaged transactions or aggressive collection strategies that are “to good to be true,” “lack economic substance,” or “lack business purpose” can result in substantial civil penalties, professional licensing issues, and injunctions. When the Government believes that the individuals involved intentionally violated the rules – lying, cheating, or stealing – the matter can quickly move into the criminal realm. This panel will review what causes the Government to initiate a criminal tax investigation, the roles of IRS-CI, the Justice Department’s Tax Division, and the U.S. Attorney’s Office, the transactions and structures currently targeted by the IRS, and “ripped from the headlines” criminal tax prosecutions.
Click here to register.

Bryan C. Skarlatos Participates In A Panel Entitled "When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice" At The 81st Institute On Federal Taxation
2022-11-17 20:15 - 21:55 (America/New_York)
Bryan C. Skarlatos chairs a panel titled “When Are You Crossing A Line? Real Life Ethical Issues In Everyday Tax Practice” on November 17, 2022 at the 81st Institute on Federal Taxation in San Diego, California.
Panel Description: How sure do you have to be before you tell a client it is okay to take a deduction or defer income? Do you have to audit a client’s records or can you just rely on what the client says? After the return has been filed, how do you handle an audit when you know the client’s tax return is wrong? What do you do if the information you submitted to the IRS is not accurate? When do you have to worry about conflicts of interest? While the answers to these questions may not always be clear, the law and related ethical standards provide very specific rules to help find the answers. This panel of expert practitioners addresses these and other thorny ethical issues that arise in everyday tax practice through the use of hypothetical examples. This program is essential for tax professionals who want to stay on the right side of the line.
Panelists:

Chair: Bryan C. Skarlatos, Esq., Partner, Kostelanetz LLP, New York, NY
Michael J. Desmond, Esq., Partner, Gibson, Dunn & Crutcher, Los Angeles, CA and Washington, DC
Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

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Megan L. Brackney Participates In A PLI Panel Entitled "Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know"
2022-11-18 13:15 - 14:15 (America/Chicago)
Megan L. Brackney participates in a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” on November 18, 2022 at the Practicing Law Institute’s Tax Strategies 2022 program.
Panel Description: Panelists discuss ethical rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit. Additionally, panelists describe the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Panelists:

Megan L. Brackney
Jenny L. Johnson
Bradley M. Seltzer

Click here for more information and to register.

Caroline D. Ciraolo Moderates A Panel Titled "From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime" At The 2022 IRS Representation Conference
2022-11-18 13:45 - 14:45 (America/New_York)
Caroline D. Ciraolo moderates a panel titled “From the Frying Pan and Into the Fire: Handling Audits Under the New Centralized Partnership Audit Regime” at the 2022 IRS Representation Conference.
Panel Description: Audits of partnerships were previously governed by special procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). At the start of the 2018 tax year, partnership audits became governed by the new Centralized Partnership Audit Regime. The new regime is dramatically changing the way audits are handled and practitioners must understand the new rules to effectively represent their clients and avoid costly mistakes. This panel will discuss the differences between TEFRA and the BBA, and preparing for and effectively managing a partnership audit under the new rules.
Moderator:

Caroline D. Ciraolo, Esq., Kostelanetz LLP, Washington, DC

Panelists:

Philip J. Wilson, CPA, Marcum, LLP, Costa Mesa, CA
Steven Hurok, Esq., Citrin Cooperman & Company LLP, New York, NY
G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA

Click here to register. Please note the event will be taking place in ET time.

Megan L. Brackney Participates In A Tax Litigation And Controversy Panel At The WSTA-WSTEC 2022 Fall Tax Conference
2022-11-22 11:30 - 12:45 (America/New_York)
Megan L. Brackney participates in a tax litigation and controversy panel on November 22, 2022 at the 2022 Fall Tax Conference co-sponsored by the Wall Street Tax Association and the Wall Street Tax Educational Corporation.
Panel Description: Panelists discuss implications of the recent decision on agencies’ regulatory power as well as IRS notices and regulations subject to the APA notice-and-comment process.
Panelists:

Megan L. Brackney, Partner, Kostelanetz LLP
Miriam Fisher, Partner, Latham & Watkins LLP
Larry Hill, Partner, Steptoe & Johnson LLP

Moderator:

Kevin Salinger, Head of Tax Counsel & Advisory, Jefferies

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Bryan C. Skarlatos Presents On "Tax Ethics: Best Practices for Ensuring Compliance With Circular 230" At A Strafford Live Webinar
2022-11-22 13:00 - 14:50 (America/New_York)
Bryan C. Skarlatos presents on “Tax Ethics: Best Practices for Ensuring Compliance With Circular 230” on November 22, 2022 at a Strafford live webinar.
Panel Description:
This course discusses Circular 230 concerns regarding ethical encounters facing tax professionals, including how current norms impact the profession. The panel examines best practices to ensure compliance and avoid penalties.
Fulfilling one’s professional obligations as a tax practitioner has never been easy, and the disruption caused by more practitioners working from home compounds the profession’s ethical challenges. This webinar explores how Circular 230, statutory penalties, and other applicable rules apply in everyday situations and how technological changes expose tax professionals to potential sanctions.
To practice before the IRS, tax practitioners must comply with standards outlined in Circular 230, which covers conflicts of interest, the duty of confidentiality, knowledge of a client’s omission, and other issues, including the duty of supervisors to ensure that others in their firm comply with the rules. Knowing the requirements of Circular 230, which complements the professional standards adopted by accounting societies and bar associations, is vitally important.
Speaker:

Bryan C. Skarlatos, Esq., Kostelanetz LLP

Click here to register.

Caroline D. Ciraolo Participates In A Panel Titled "Tax Controversy" At The IFA USA 3rd Annual Winter Conference
2022-11-30 11:00 - 12:20 (America/New_York)
Caroline D. Ciraolo speaks about tax controversy at the IFA USA 3rd Annual Winter Conference on November 30, 2022.
Description:
This panel addresses current IRS enforcement efforts, dispute resolution procedures, and litigation of international tax issues. Particular attention is paid to recent transfer pricing cases and government-to-government resolution.
Moderator:

Steve Wrappe, Grant Thornton

Panelists:

Caroline D. Ciraolo, Kostelanetz LLP
Philip Baker, University of Oxford
Thomas Greenway, KPMG
James Kelly, IRS

Click here to register.

Caroline D. Ciraolo Participates In A Panel Titled "Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know" At The Tax Strategies 2022 Conference
2022-12-09 13:15 - 14:15 (America/Los_Angeles)
Caroline D. Ciraolo joins a panel titled “Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know” at the Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2022 conference in Los Angeles, CA.
Panel Description:
Ethical rules related to advising clients on corporate transactions, including tax motivated transactions, and the pitfalls encountered by the advisor at every stage – from the planning of the transaction, to providing tax opinions and recommending return positions, to dealing with the IRS in audit; the ethical rules and standards derived from the Internal Revenue Code, Circular 230, the AICPA Statements on Standards for Tax Services, and the ABA Model Rules of Professional Conduct.
Panelists:

Caroline D. Ciraolo, Esq., Kostelanetz LLP, Washington, DC
Sandra R. Brown, Hochman Salkin Toscher Perez P.C., Beverly Hills, CA
Bradley M. Seltzer, Eversheds Sutherland, LLP, Washington, DC

Click here to register. Please note the event will be taking place in PST time.

Michael Sardar and Don Fort Participate In A Panel Titled "Criminal Tax Workshop" At The 39th Annual National Institute On Criminal Tax Fraud And The 12th Annual National Institute On Tax Controversy
2022-12-12 14:30 - 17:00 (America/Los_Angeles)
Michael Sardar and Don Fort participate in a panel titled “Criminal Tax Workshop” at the 39th Annual National Institute on Criminal Tax Fraud and the 12th Annual National Institute on Tax Controversy.
Panel Description:
This popular workshop teaches strategies and techniques for handling sensitive civil examinations and criminal investigations, and defending a criminal prosecution. The workshop addresses when to anticipate a criminal referral; IRS Special Agent interviews of the taxpayer or preparer; representation of a target, subject or witness in a criminal investigation; how to approach a Department of Justice conference; procedural and trial issues that every criminal tax defense attorney should know; when and how to argue tax loss issues; effective plea negotiations; and sentencing strategies. The workshop includes a “criminal tax toolkit” of practice tips prepared by experienced practitioners. CLE credit is offered for this event.
Panelists:

Michael Sardar, Partner, Kostelanetz LLP
Don Fort, Director of Investigations, Kostelanetz LLP
Justin Gelfand, Partner, Margulis Gelfand
Elizabeth Caryl Hadden, Deputy Division Counsel/Deputy Associate Chief Counsel (Criminal Tax),
Internal Revenue Service
Edward M. Robbins, Jr., Partner, Hochman Salkin Toscher Perez, P.C.
Michelle Feit Schwerin, Shareholder, Capes Sokol Goodman & Sarachan PC
Richard Speier, Jr., Consultant, Richard Speier & Associates
Lacey E. Strachan, Attorney, Hochman Salkin Toscher Perez, P.C.
Jeffery D. Trevillion, Jr., Director, Crowe & Dunlevy

Click here to register. Please note the event will be taking place in PST time.

Caroline D. Ciraolo Moderates A Panel Titled "The Use of Mail and Wire Fraud Charges in Tax Cases and its Consequences" At The 39th Annual National Institute On Criminal Tax Fraud And The 12th Annual National Institute On Tax Controversy
2022-12-13 13:45 - 14:45 (America/Los_Angeles)
Caroline D. Ciraolo moderates a panel titled “The Use of Mail and Wire Fraud Charges in Tax Cases and its Consequences” at the 39th Annual National Institute on Criminal Tax Fraud and the 12th Annual National Institute on Tax Controversy.
Panel Description:
Mail fraud and wire fraud charges work their way into many criminal tax indictments. The distinguished panel will discuss why they are included, the Department of Justice’s guidelines including such charges, and the possible consequences to those charged.
Moderator:

Caroline D. Ciraolo, Esq., Kostelanetz LLP, Washington, DC

Click here to register. Please note the event will be taking place in PST time.

Caroline D. Ciraolo Participates In A Panel Titled "How to Be an Ally to Your Diverse Colleagues in Tax Practice" At The 39th Annual National Institute On Criminal Tax Fraud And The 12th Annual National Institute On Tax Controversy
2022-12-13 17:00 - 18:00 (America/Los_Angeles)
Caroline D. Ciraolo participates in a panel titled “How to Be an Ally to Your Diverse Colleagues in Tax Practice” at the 39th Annual National Institute on Criminal Tax Fraud and the 12th Annual National Institute on Tax Controversy.
Panel Description:
Diversity and inclusion are central to providing the best service to clients. Diversity in representation and experience can foster a broader range of views in how to approach a matter. Diversity cannot thrive in the absence of inclusion and advancement. This panel will discuss how each of us can be a better ally to our colleagues, and as a result become better counsel to our clients. CLE credit is offered for this event.
Panelists:

Caroline D. Ciraolo, Partner, Kostelanetz LLP
Frank Agostino, President, Agostino & Associates PC
Hon. Elizabeth Copeland, Judge, United States Tax Court
Beverly Winstead, Founder, The Law Office of Beverly Winstead, LLC, and Director, LITC, University of Maryland Carey School of Law

Click here to register. Please note the event will be taking place in PST time.

Bryan C. Skarlatos Participates In A Panel Titled "What Every Tax Litigator Needs to Know About the Appeal of Their Civil or Criminal Case" At The 39th Annual National Institute On Criminal Tax Fraud And The 12th Annual National Institute On Tax Controversy
2022-12-14 10:00 - 11:00 (America/Los_Angeles)
Bryan C. Skarlatos participates in a panel titled “What Every Tax Litigator Needs to Know About the Appeal of Their Civil or Criminal Case” at the 39th Annual National Institute on Criminal Tax Fraud and the 12th Annual National Institute on Tax Controversy.
Panel Description:
Most practitioners have tried tax cases but fewer have the experience of appealing a tax case. The case does not always end with the trial court’s judgment. Many lessons can be learned by the trial lawyer knowing the problems encountered on appeal and how they might have been avoided. This experienced group of tax litigators and appellate practitioners will discuss how to become a better trial lawyer in tax cases. CLE credit is offered for this event.
Panelists:

Bryan C. Skarlatos, Partner, Kostelanetz LLP
Diana Erbsen, Partner, DLA Piper LLLP
David Foster, Partner, Skadden, Arps, Slate, Meagher & Flom LLP
Alexander Patrick Robbins, Assistant United States Attorney, U.S. Department of Justice

Click here to register. Please note the event will be taking place in PST time.

Megan L. Brackney Participates In A Webinar Titled "Tax Teaching and Adjunct Opportunities" For The American Bar Association
2023-01-10 13:00 - 14:00 (America/New_York)
On January 10, 2023, Megan L. Brackney participates in a webinar titled “Tax Teaching and Adjunct Opportunities” for the American Bar Association.
Webinar Description: This webinar is designed for tax practitioners who are current or prospective adjunct professors. The panel of experienced adjunct professors discusses best practices for teaching tax classes to JD and LLM students, as well as ideas to promote the Tax Section to law students.
Panelists:

Megan L. Brackney, Partner, Kostelanetz LLP
Alexander Lee, Loyola Marymount University, Los Angeles, CA
Scott Levine, Georgetown University, Washington, D.C.

Moderator:

Jennifer Kowal, Loyola Marymount University, Los Angeles, CA

Click here for more information and to register.

Heather Fincher Participates In A Webinar Titled "U.S. GILTI Anti-Deferral Rules and Tax Compliance: Reporting Issues, Navigating Forms 5471, 8992, 8993, and 1118" For Strafford's CLE/CPE Program
2023-01-11 13:00 - 14:30 (America/New_York)
In this CLE/CPE course, Heather Fincher provides tax professionals with an in-depth discussion of the challenges posed to U.S. businesses that must report their global intangible low-taxed income (GILTI). The panel provides tax professionals with guidance on the challenges of the GILTI rules and discusses calculating GILTI and the Section 250 deduction, particularly for individual taxpayers; reporting compliance; and navigating Forms 5471, 8992, 8993, and 1118. The panel also offers tax planning tips to minimize the tax liability of taxpayers with CFC interests.
Panelists:

Heather Fincher, Kostelanetz LLP (Washington, DC)
Melody C. Horton, Arc Advisors (New York, NY)
Michael Dana, Husch Blackwell (Washington, DC)

Click here for more information and to register. Please note that the event will be taking place in EST time.

Bryan C. Skarlatos Presents On "Tax Basics for Matrimonial Judges" At The New York State Judicial Institute New Judges Seminar
2023-01-11 16:15 - 17:15 (America/New_York)
On January 11, 2023, Bryan C. Skarlatos presents on “Tax Basics for Matrimonial Judges” for the New Judges Seminar at the New York State Judicial Institute.
Seminar Description:
The effect of tax considerations on divorcing parties can impact the decisions made during a matrimonial proceeding. Therefore, it is important for judges to accurately evaluate tax return information. This session teaches judges how to read a tax return proficiently and determine the actual income, assets, and cash flow available to the parties involved in a divorce action.
Speak

Bryan C. Skarlatos, Esq., Kostelanetz LLP

Michael Sardar And Christopher Ferguson Present "Handling a Sensitive IRS Audit" At The American Society of Tax Problem Solvers Winter Conference
2023-01-12 14:10 - 15:10 (America/New_York)
Michael Sardar and Christopher Ferguson present “Handling a Sensitive IRS Audit” at the American Society of Tax Problem Solvers Winter Conference.
Presentation Description:
Navigating the Internal Revenue Service audit process can be a daunting task for anyone. Handling sensitive audits that are likely to uncover significant income underreporting and deficiencies, or worse, fraud, add to these challenges. In the most sensitive of audits, the stakes can be quite high, potentially implicating not just additional tax and/or penalties, but a taxpayer’s liberty.
This session covers strategies for minimizing the risk presented by such audits and guidance on how to determine when an audit may be turning into a criminal investigation, including the questions to ask and the signs to look out for. Issues of privilege and the right to assert a taxpayer’s 5th Amendment rights are also discussed.
Presenters:

Michael Sardar, Partner, Kostelanetz LLP
Christopher Ferguson, Partner, Kostelanetz LLP

Click here to register.
